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Hanford Site Biological Resources Mitigation Strategy 4 iii

This document is intended to describe the recom-mended process that should be followed to ensurethat Hanford Site missions are accomplished with-out significant impacts to important biologicalresources. Mitigation may entail both the preventionof adverse impacts and the replacement of resourcesif impact prevention is not practical. However, thehighest priority for mitigation should always beprevention of adverse impacts, and all avenuesfor prevention should be explored before resourcereplacement is considered. This policy will ulti-mately be best for the resources of concern andwill least affect project budgets and schedules.

Mitigation is a series of prioritized actions thatreduce or eliminate adverse impacts to biologicalresources. The hierarchy for these actions is to:1) avoid the impact, 2) minimize the impact,3) rectify impacts onsite, and 4) compensate forthe impact away from the site. This hierarchy canbe applied to all species and habitats of concern.Avoidance and minimization are considered impactprevention, while rectification and compensationare considered resource replacement.

Specific resources that will be subject to mitigationof adverse impacts are defined in the BiologicalResources Management Plan (BRMaP) for the HanfordSite (DOE 2001a). The mitigation strategy describedhere applies only to mitigable resources as definedin BRMaP, not to all species and/or habitats on theHanford Site. In general, mitigable resourcesinclude plant and animal species of concern (stateor federal endangered, threatened, candidate, orsensitive species), habitats for these species, rareor unusual plant assemblages as defined in theWashington Natural Heritage Plan (WDNR 1995),habitats with high native plant or animal diversity,

habitats lacking significant anthropogenic disturb-ance, and habitats specifically protected understate or federal regulations, such as jurisdictionalwetlands.

The emphasis on biological resource values impliedin this document is not meant to override otherimportant considerations such as human health,worker safety, or even budget concerns. Biologicalresource values should be evaluated in tandemwith these other considerations. Except in unusualor emergency situations, these considerations arenot mutually exclusive.

The Biological Resources Mitigation Strategy (BRMiS),as part of a broader biological resource policy, isdesigned to aid the U.S. Department of Energy,Richland Operations Office (DOE-RL) in balancingits primary missions of waste cleanup, technologydevelopment, and economic diversification withits stewardship responsibilities for the biologicalresources it administers. This strategy will beapplied to all DOE-RL programs as well as allcontractor and sub-contractor activities.

This BRMiS will fulfill the following needs:

• ensure consistent and effective implemen-tation of mitigation recommendations andrequirements.

• ensure mitigation measures for biologicalresources meet the responsibilities of DOE-RLunder both the National Environmental PolicyAdministration (NEPA) and the Comprehen-sive Environmental Response, Compensationand Liability Act of 1980 (CERCLA).

iv 4 Hanford Site Biological Resources Mitigation Strategy

• enable Hanford Site development and cleanupprojects to anticipate and plan for mitigationneeds via early identification of mitigationrequirements.

• provide guidance to Hanford personnel inimplementing mitigation in a cost-effective andtimely manner.

• preserve and protect Hanford’s highly valuedbiological resources while facilitating balanceddevelopment and site cleanup activities.

The BRMiS provides guidance on accounting forhabitat protection or improvement as part of theproject planning process. This strategy also providesguidance and a reference for the preparation ofproject-specific Mitigation Action Plans (MAPs)under NEPA implementation procedures (10 CFR1021). Although this strategy is neither intended toreplace or define the specific contents of futureMAPs—nor to provide specific procedures toconduct habitat improvements or protection forspecific projects—it will aid and simplify thepreparation of future MAPs.

The mitigation strategy described in this documentis based on the following three principles:

1. A project should begin mitigation with avoid-ance of deleterious impacts to valued biologicalresources and move to the next action levelonly if all reasonable options for the previouslevel are exhausted.

2. If, early in a project’s life, careful considerationis given to avoiding and minimizing adverseimpacts before they occur, the need for moreexpensive forms of mitigation (rectification andcompensation) can be greatly reduced or elimi-nated. This will save time, money, and is mostbeneficial to resources of concern.

3. When residual adverse impacts to resources ofconcern remain after avoidance, minimization,and onsite rectification, compensatory mitiga-tion should be performed, preferably as part ofa centralized mitigation bank.

Avoidance and minimization of adverse impactsare normally accomplished during the impactmanagement portion of the ecological compliancereview process. This is a process by which potentialadverse project impacts are identified, and means

to alleviate those impacts are devised and incorpo-rated into the project plans. This process is describedin detail in the Ecological Compliance AssessmentManagement Plan (ECAMP) (DOE 1995a).

The BRMiS provides the framework for compen-satory mitigation via rectification and whilestressing the overriding importance of initialavoidance and minimization of adverse impacts.Mitigation requirements should be determined onthe basis of impacts to specific resources or habitats,and not on a strict land area basis. This policy isintended to encourage projects to locate in areasof low existing habitat value because mitigationactions, if any, required for such areas will beconsiderably less than those associated with high-quality habitat areas.

Quantification of habitat value should be basedon the habitat evaluation procedures developed bythe U.S. Fish and Wildlife Service (USFWS). Theseprocedures also should be used to determine miti-gation threshold levels, below which compensatorymitigation would not be required.

Projects required to perform compensatory mitiga-tion should consider participation in a centralizedcompensatory mitigation system or bank. Mitiga-tion banking is the establishment of habitat formanaged resources (or establishment of theresources themselves) in areas other than at theimpact site to compensate for unavoidable habitatvalue losses that result from project development.

In a true mitigation bank, the resource establish-ment is performed in anticipation of future resourcelosses. In a pseudo-bank, the resources are estab-lished as the impacts occur. Use of a centralizedbank (either a true- or pseudo-bank) for compen-satory mitigation will simplify the compensationprocess for all projects because the goals, method-ologies, and locations for compensatory mitigationwill be pre-defined.

A project will not be required to design and engi-neer its own compensatory mitigation actions, butwould simply pay into the established system orbank. A bank will enable the mitigation require-ments for numerous projects to be coordinated andconducted in a manner that will result in thegreatest overall improvement in habitat valuewhile reducing collective project costs because ofthe economy of scale.

Projects are allowed to pay into the bank at anytime, but the preferred method of bank operation

Hanford Site Biological Resources Mitigation Strategy 4 v

is to have habitat improvements under way beforeuse of the credits. This will help ensure that levelsof the affected biological resources do not declinebetween the time of project impact and the timewhen suitable improved habitat is available tosupport the resources. Project budgets should bedeveloped to allow credits to be purchased early inthe life of project. Mitigation bank credits and debitswill be calculated on the basis of habitat value.

The Assistant Manager for Infrastructure and Clos-ure (AMC) through the Closure Division (CLO)will be the focal point for the development andcoordination of site- and program-wide biologicalresources mitigation policies and guidance. Speci-fic CLO responsibilities include the following:

• ecological assessments and impact manage-ment, including development of avoidance andminimization recommendations for projectimpacts

• mitigation reporting and monitoring of mitiga-tion areas or banks, including (when applicable)the development of an accounting system forboth bank credits (resulting from habitatimprovement actions) and bank debits(resulting from adverse impacts to biologicalresources that require compensatory mitigation)

• development of models needed to quantifyhabitat value losses due to project impacts andhabitat value gains resulting from improve-ment actions

• identification of areas that are ecologicallysensitive or possess unique habitat characteris-tics, designation of them as such in land useplans and maps, and assurance that this factoris included in siting decisions

• identification and evaluation of specific areas tobe used for a mitigation bank or for compensa-tory mitigation areas

Early in the project planning process, all Officeswithin DOE-RL will:

• identify biological resource issues

• identify to CLO adverse impacts to mitigableresources that may result from programactivities

• incorporate recommendations for the avoidanceand minimization of adverse impacts tobiological resources when practicable, andperform rectification or compensatory miti-gation for unavoidable impacts

• budget for mitigation requirements.

The Pacific Northwest National Laboratory (PNNL)performs ecological compliance reviews, except forsome assessments performed by the EnvironmentalRestoration Contractor (ERC)/River CorridorContractor (RCC). Environmental compliancereviews will document the presence of any speciesor habitats of concern at a site and will provideavoidance and minimization recommendations(when applicable).

The PNNL, in coordination with other site con-tractors, will develop models to determine habitatreplacement ratios and mitigation threshold levelsand quantify mitigation requirements and success.PNNL also will assist DOE-RL in monitoringmitigation areas and preparing annual reportsconcerning mitigation, as requested.

The other principal Hanford contractors will beresponsible for implementing habitat improve-ments within mitigation areas or banks and for thecontinued operation and maintenance of mitiga-tion areas or banks, or portions thereof, that areattributable to their activities.

Complete implementation of the strategy describedin this document will require developing habitatevaluation models specific to Hanford. Thesemodels are not complete, and therefore, cannot beused to determine the quantity of habitat value lostas a result of Hanford activities, the quantity ofhabitat value gained through replacement orimprovement, or mitigation threshold levels. IfHanford Site operations are to meet the intent, ifnot the letter, of this strategy, specific guidanceapplicable to normal Site activities is required. Thus,until Site-specific habitat evaluation models areavailable, the principles outlined in the box on thenext page will guide mitigation on the Hanford Site.

Substitution of actions with equivalent benefits forany of the basic replacement unit requirementswill be developed and/or considered on a case-by-case basis.

vi 4 Hanford Site Biological Resources Mitigation Strategy

Interim Mitigation Guidance

• Prevention of adverse impacts to mitigable resources is considered a best management practice in project

planning and siting. All projects will consider (and adopt when practical) means to avoid and/or minimize

impacts.

• All projects should request an assessment of potential impacts to mitigable resources as early as possible in the

planning process. This will allow for project modifications that prevent adverse impacts to be incorporated

during preliminary instead of final design, and if habitat replacement is still needed, appropriate plans can be

developed.

• In those cases when replacement mitigation is appropriate, the habitat improvements for all such projects will

be coordinated, at least to the level of one or more common mitigation areas. If the habitat replacement for

several projects can be grouped and performed under a single sub-contract, that level of coordination should be

pursued.

• Mitigation Thresholds (applicable to the area of mitigable habitat, not to the entire impact area):

- Replacement mitigation is not required within the 300 Area (fenced areas), 400 Area, and the perimeter

roads of the 100 Areas. Replacement mitigation is not required within much of the 200 Areas.

- In the northeast corner of 200-West Area and the southern portion of the 200-East Area (see Figure 7) the

mitigation threshold will be 5 ha (12 acres) of mitigable habitat. In these areas, no distinction is made

between rectification and compensatory mitigation, and replacement will be at a ratio of 1:1 (see below).

- In the 200 Areas corridor (Figure 7) the mitigation threshold will be 1 ha (2.5 acres) of mitigable habitat.

- In all other portions of the Hanford Site (the 600 Area) the mitigation threshold will be 0.5 ha (1.25 acre) of

mitigable habitat. Specific areas where this threshold may apply are shown in Appendix D of BRMaP.

• Disturbances smaller than the applicable threshold will not require replacement mitigation.

• Replacement Ratios

- Rare plants—1:1 based on individuals

- Wetlands and riparian—2:1 based on area

- Upland late-successional shrub-steppe—1:1 for rectification; 3:1 for compensatory mitigation based on area.

• Compensatory mitigation occurs away from the site of disturbance. Rectification (when possible) occurs at the

site of disturbance within two planting seasons of the initial impact; if the impact cannot be rectified within two

planting seasons, then compensatory mitigation (at 3:1) will be required.

• Replacement Units for late-successional shrub-steppe will consist of 20 transplanted large shrubs/ha (8/acre),

1000 seedlings/ha (400/acre), and a native perennial grass understory.

- Rectification at a replacement ratio of 1:1 will require one Replacement Unit per hectare of mitigable habitat

disturbed; compensatory mitigation at a replacement ratio of 3:1 will require three Replacement Units per

hectare of mitigable habitat disturbed

- Appropriate replacement units for other mitigable habitats will be developed as needed.

• Alternatives to any of the interim requirements may be developed on a case-by-case basis, as long as the

functional aspects of the requirements are met.

Hanford Site Biological Resources Mitigation Strategy 4 vii

Executive Summary ............................................................................................................................................... iii

1 .0 Purpose and Scope of the Mitigation Strategy ....................................................................................... 1

1.1 Overview of the Hanford Site Biological Resources Mitigation Strategy ............................... 1

1.2 Relationship of BRMiS to Other Resource Management Documents ...................................... 2

1.2.1 Biological Resources Management Plan .......................................................................... 2

1.2.2 Ecological Compliance Assessment Management Plan ................................................. 2

1.2.3 Other Site-Wide Guidance ................................................................................................. 2

1.3 Mitigation Order of Priorities ........................................................................................................ 3

1.4 Hanford Site Mitigation Process .................................................................................................... 4

1.5 Mitigation Versus Restoration ....................................................................................................... 6

1.6 Biological Resources Covered Under BRMiS .............................................................................. 6

2.0 Requirements for Mitigation ..................................................................................................................... 9

3.0 Roles and Responsibilities ......................................................................................................................... 13

3.1 Department of Energy .................................................................................................................... 13

3.2 Contractors ....................................................................................................................................... 14

4.0 Triggers for Mitigation ............................................................................................................................... 17

4.1 Basis for Use of Units of Habitat Value ........................................................................................ 17

4.2 Quantification of Habitat Value..................................................................................................... 17

4.3 Mitigation Threshold Levels .......................................................................................................... 18

4.4 Interim Mitigation Threshold Guidelines .................................................................................... 20

5.0 Implementation ........................................................................................................................................... 23

5.1 Mitigation Strategy Goals ............................................................................................................... 23

5.2 Identifying Mitigation Needs ........................................................................................................ 23

5.3 Mitigation at a Project Site .............................................................................................................. 23

viii 4 Hanford Site Biological Resources Mitigation Strategy

5.4 Mitigation Away from a Project Site and Mitigation Banking .................................................. 24

5.4.1 Bank Objectives and Currency .......................................................................................... 25

5.4.2 Bank Sites, Protection, and Control .................................................................................. 25

5.4.3 Bank Operation Policy ........................................................................................................ 26

5.4.4 Bank Monitoring and Reporting ....................................................................................... 27

5.5 Mitigation Levels and Ratios ......................................................................................................... 27

5.5.1 Mitigation Levels ................................................................................................................. 27

5.5.2 Mitigation Replacement Ratios ......................................................................................... 27

5.5.3 Interim Replacement Ratio Guidelines ............................................................................ 31

5.5.4 Mitigation Replacement Units ........................................................................................... 31

5.6 Mitigation/Restoration Methods .................................................................................................. 32

5.7 Native Plant Nursery and Grass Farm ......................................................................................... 32

5.7.1 Native Plant Nursery .......................................................................................................... 32

5.7.2 Native Grass Farm ............................................................................................................... 32

6.0 Locations for Mitigation Areas or Banks ................................................................................................. 35

6.1 Prioritized, Landscape-Scale Siting Criteria ................................................................................ 35

6.2 Technical Siting Criteria .................................................................................................................. 36

6.3 Methods for Selecting a Mitigation Area for Compensation .................................................... 37

7.0 Mitigation Monitoring, Reporting, and Contingencies ......................................................................... 39

7.1 Mitigation Performance Measures and Monitoring ................................................................... 39

7.2 Performance Reporting ................................................................................................................... 39

7.3 Contingencies ................................................................................................................................... 40

8.0 Mitigation for Plant Species of Concern .................................................................................................. 41

8.1 Plant Species of Concern ................................................................................................................ 41

8.2 Mitigation Procedures ..................................................................................................................... 41

8.2.1 Avoidance ............................................................................................................................. 42

8.2.2 Minimization ........................................................................................................................ 42

8.2.3 Rectification and Compensatory Mitigation ................................................................... 42

9.0 Project-Specific Mitigation Action Plans ................................................................................................. 43

10.0 References .................................................................................................................................................... 45

11.0 List of Acronyms and Initialisms ............................................................................................................. 47

12.0 Glossary........................................................................................................................................................ 49

Hanford Site Biological Resources Mitigation Strategy 4 ix

1 Integration of Mitigation Strategy with Other Resource and Management Plans ........................... 3

2 Mitigation Decision Tree and Relationship of Plans.............................................................................. 5

3 Example of Restoration and Mitigation as Applied to a Remediation Project .................................. 7

4 Waste Site Remediation Decision Tree for Mitigation ........................................................................... 7

5 Organization Structure and Flow for Implementation of Biological Resources Mitigation ............ 14

6 Balance of Habitat Units Lost from Project Impacts and Gained Through Mitigation .................... 19

7 Interim Mitigation Threshold Regions on the 200 Areas Plateau ........................................................ 21

8 Levels of Mitigation Involving Habitat Improvement .......................................................................... 28

9 Comparison of Spatial- or Quality-Based Replacement Ratios ........................................................... 28

10 Comparison of Habitat Improvement Potential at Three Possible Mitigation Sites ......................... 37

1 Types of Mitigation for Biological Resource Impacts ............................................................................ 4

2 Acts, Regulations, and Executive Orders Pertaining to Mitigation .................................................... 9

3 Additional Act Potentially Applicable to Specific Situations on the Hanford Site ........................... 11

4 Federal and State Policies and Guidelines for Mitigation .................................................................... 12

5 Interim Mitigation Thresholds for Late-Successional Sagebrush Steppe Habitat Areas ................. 20

6 Examples of Habitat Improvement Levels for Mitigating Shrub-Steppe Impacts ............................ 28

7 Sagebrush Survival Rates for Hanford Site Mitigation/Restoration Projects ................................... 30

Hanford Site Biological Resources Mitigation Strategy 4 1

The mission of the Department of Energy (DOE)on the Hanford Site is to: 1) clean up the HanfordSite following the Site’s earlier mission of weaponsmaterial production and energy development,2) provide scientific and technical excellence tomeet global needs, and 3) partner in the economicdiversification of the region. While pursuing thismission, DOE is obligated to appropriately man-age the natural resources under its stewardship.

To facilitate a balance between mission elementsand stewardship obligations, this BiologicalResources Mitigation Strategy (BRMiS), as onecomponent of an overall policy described in theHanford Site Biological Resources Management Plan(BRMaP) (DOE 2001a), will:

• ensure consistent and effective implementationof mitigation recommendations andrequirements

• ensure that mitigation measures for biologicalresources meet the responsibilities of DOEunder both the National Environmental PolicyAct (NEPA) and the Comprehensive Environ-mental Response, Compensation, and LiabilityAct (CERCLA)

• enable Hanford Site development and cleanupprojects to anticipate and plan for mitigationneeds via early identification of mitigationrequirements

• provide guidance for implementing cost-effective and timely mitigation

• preserve Hanford’s biological resources whilefacilitating balanced development and cleanupactivities.

Mitigation is a series of prioritized actions thatreduce or eliminate adverse impacts to biologicalresources. These actions include avoidance,minimization, onsite rectification, and compensa-tory mitigation. The basis of this strategy is that aproject should begin mitigation at the avoidancelevel of the hierarchy, and only move to the nextlevel if all reasonable options at the previous levelare exhausted.

Mitigation actions that rely on improving habitat(rectification and compensatory mitigation) are themain subject of BRMiS. Habitat improvement maybe necessary for projects that eliminate or degradehabitat. However, mitigation actions based onavoidance or minimization of adverse impacts(such as changes to project timing or location) arethe most important components of the mitigationstrategy. These mitigation actions are more fullyaddressed in the Ecological Compliance AssessmentManagement Plan (ECAMP) (DOE 1995a). Mitiga-tion of impacts to species listed under the Endan-gered Species Act (ESA) will be determined underthe consultation requirements in Section 7 ofthe ESA.

The BRMiS provides guidance on accounting forhabitat protection or improvement as part of theproject planning process. This strategy also pro-vides guidance and a reference for the preparationof project-specific mitigation action plans (MAPs)under the DOE National Environmental PolicyAct (NEPA) implementation procedures (10 CFR1021). Although this strategy is not intended toreplace or define the specific contents of future

2 4 Hanford Site Biological Resources Mitigation Strategy

MAPs, it will aid and simplify their preparation.Section 9 of this document provides a brief overviewof suggested contents for project-specific MAPs.Additionally, BRMiS is not intended to providespecific procedures to conduct habitat improve-ment or protection measures for specific projects.

Finally, BRMiS’s and BRMaP’s emphasis on bio-logical resource values is not meant to overrideother considerations such as human health, workersafety, or budget concerns. Biological resourcevalues should be evaluated in tandem with theseconsiderations, and except in unusual or emerg-ency situations, these considerations will not bemutually exclusive.

The BRMiS is one of several documents thatdescribe how biological and other resources willbe monitored and managed on the Hanford Site.Figure 1 provides an overview of these documentsand how they relate to each other and variousprojects and programs. Subsequent sectionsdescribe each related document in more detail.

The BRMaP (DOE 2001a) is the umbrella documentfor biological resource management issues for theHanford Site. This plan describes the biologicalresources on the Hanford Site and their regionalcontext; defines what resources need monitoring,protection, impact assessment, and mitigation;prescribes resource management goals and objec-tives; identifies areas on the Hanford Site thatcontain habitats or species of concern; and imple-ments an ecosystem management approach tobiological resource management on the HanfordSite. The BRMaP is prepared and updated incoordination with the Hanford Site ComprehensiveLand-Use Plan Environmental Impact Statement(HCP-EIS) (DOE 1999), and other site-wideguidance.

The BRMiS and the ECAMP are second-tierdocuments under BRMaP. The BRMaP defineswhich biological resources will be assessed underECAMP and which resources require mitigationunder BRMiS.

The ECAMP (DOE 1995a) describes the processthrough which project impacts to biologicalresources are assessed and evaluated via theecological compliance review process detailed inECAMP. For most projects, this normally will bethe first, and usually the only, interaction withDOE’s biological resource management policies.During the ecological compliance review, the siteof a proposed project is inspected and evaluatedfor potential impacts to biological resources. Theresults of the evaluation, including mitigationrecommendations, if any, are reported back to theproject to support the project NEPA documentation.

Specific resources considered during the revieware those BRMaP determines to be in need ofimpact assessment. Impact management also isdescribed in ECAMP. This is an interactive processbetween project and ecological compliance assess-ment staff. Impact management identifies meansby which the project can be temporally, spatially,or structurally altered to avoid and/or minimizeadverse impacts to resources of concern. Thisaccomplishes the first two stages of mitigation (seeSection 1.3), and in many cases, will eliminate orgreatly reduce the need for rectification or com-pensatory mitigation, thereby reducing mitigationcosts.

Because of both the field assessments and theimpact management components of ECAMP, it isan integral part of the Hanford Site mitigationstrategy. In most cases, it is expected that projectswill be able to assess and complete their mitigationrequirements within the scope of ECAMP withoutusing the additional mitigation strategy compo-nents described in the BRMiS.

Other site-wide management plans and docu-ments have direct bearing on biological resourcemanagement on the Hanford Site. For example,the HCP-EIS (DOE 1999) provides guidance forHanford Site land-use planning within an ecosys-tem management and sustainable developmentframework. This includes analyses of land areaneeds for various programs such as waste man-agement and environmental restoration, and


general designations of areas considered sensitiveon the basis of ecological, cultural, and historicalcriteria. Coordination between BRMaP and theHCP is essential for proper identification of biolog-ically sensitive areas, siting mitigation areas, andto aid in siting new facilities to minimize impactsto sensitive and/or mitigable resources.

The Draft Hanford Cultural Resources ManagementPlan (DOE 2001b) affects the siting of facilities andmitigation areas. Cultural values are considered inBRMaP in designating sensitive biological resources,such as plants considered sacred by local tribes,and for siting mitigation areas. Cultural resourcereviews are performed concurrently with theecological compliance reviews, and projectplanning data are shared by the cultural andecological review teams.

Mitigation of project impacts can range fromalterations of timing or location that allow foravoidance of impacts to a more complex and costlyapproach of replacing project-induced habitat losswith newly created habitat away from the projectsite. Table 1 shows the order of preference formitigation.

Onsite protection of quality habitat areas can alsobe a form of compensatory mitigation. Habitatprotection as mitigation is applicable if the area tobe set aside is demonstrably threatened withdestruction (USFWS Mitigation Policy 46 FR 7644 -7663). This may be difficult to demonstrate on theHanford Site. Set aside or protection as mitigationcan work well for other agencies, such as the U.S.Forest Service, which can cancel one action, such

§ New Facilities & Infrastructure

§ General Site Maintenance and Upgrades

§ Environmental Restoration Projects

SITE PROJECTS


as a timber sale, as mitigation for other types ofimpacts such as construction of roads or camp-grounds.

Another form of mitigation listed by the Councilon Environmental Quality (CEQ) and in the USFWSmitigation guidelines is to “reduce or eliminate theimpact over time.” The CEQ does not clearlydefine this form of mitigation, and as defined inthe USFWS guidelines, it resembles the monitoringrequirements described in later sections of BRMiS.Another interpretation is that the mitigation actionis the monitoring of the natural recovery after animpact and taking needed measures to preventfurther impacts. This essentially is the mode ofmitigation for small projects that (after avoidanceand minimization) impact an area of mitigablehabitat below the mitigation threshold levelsdescribed in Sections 4.3 and 4.4.

The mitigation process on the Hanford Site includesseveral steps and decision points. Figure 2 diagramsthe overall process. Most projects will require onlythe first three steps (i.e., ecological compliancereview through minimization). Larger projects, or

those that must be located in more ecologicallysignificant areas, may more appropriately use thelatter steps of the mitigation process.

The mitigation process starts with the determina-tion of need for an ecological compliance reviewas outlined in ECAMP. In general, projects thatrequire an ecological compliance review are thosethat are conducted outdoors (or inside of abandonedbuildings), especially those that also require anexcavation permit. This encompasses a wide rangeof projects—from maintenance work on the outsideof buildings to large-scale land development fornew facilities.

Historically, the majority of Hanford Site projectshave had no adverse impacts on any biologicalresources of concern. Thus, many projects haveproceeded after the ecological compliance reviewwithout additional mitigative actions. Of thoseremaining, most projects proceeded with onlyminor adjustments, such as moving the site a shortdistance or performing the action during a timethat would not impact nesting of migratory birds.These avoidance and/or minimization forms ofmitigation are covered under ECAMP as a portionof the overall site-wide mitigation strategy.

Avoidance

Minimization

Rectification

Compensation

1st

2nd

3rd

4th

Eliminate all or part of a projector alter the timing, location, orimplementation to avoid injury tobiological resources of concern

Alter proposed project (timing,location, or implementation) tominimize injury to biologicalresources of concern

Replace the biological resourceson the site to be disturbed

Replace project-induced biologi-cal resource losses away from thesite to be disturbed

Relocate a proposedexcavation from an areawith protected plantspecies to an area with-out resources of concern

Perform habit removal ata time when the nestingactivities of migratorybirds will not be disturbed

Return pre-existing plantcommunity to excavationsite

Replant mature sagebrushin a degraded area onHanford

ExampleMitigationUtilizationPreference Description of Mitigation Means


The last stages of rectification and compensatorymitigation are the focus of this document. Ifsignificant impacts remain after avoidance andminimization, then the rectification or compensa-tion required of a project will be determined usingprocedures described in Section 4.

Some projects may require onsite rectification.Rectification may include actions ranging from thereplacement of lost resources to preventing habitatdegradation, such as erosion prevention or thecontrol of invasive weeds subsequent to landdisturbance.

Compensatory mitigation may be needed if asignificant impact remains after onsite rectification.For example, an area covered by a new facility thatcannot be rectified onsite may need compensatorymitigation to mitigate for habitat loss. The long-term goal of this mitigation strategy is that mostcompensatory mitigation will be accomplished viaparticipation in a mitigation bank (see Section 5).

Perform Proposed

Action

ECR

Will Project

Impact Level II -

IV BiologicalResources?

Can Impacts beMinimized?

No

Yes

Yes

No

No

Yes

Perform Alternative

Action

Perform Modified

Action

Perform Action +Perform Action +

On-site RectificationOn-site Rectification

Perform Action + On-site

Rectification + Compensation

Away from Project Site

No

No

Yes

Yes

YesNo

Is Residual

Impact AboveThreshold?

Is Alternative

Available to Avoid

Impact?

Project that Requires an ECR

Mitigation Implemented

through ECAMP

(Subset of Overall Strategy)

Mitigation Implemented through BRMiS

IsResidual Impact

to Level III or IV

Resources AboveThreshold?

CanImpacts to Level

III or IV Resourcesbe Rectified at

Project Site?


Confusion can arise when terms or concepts, suchas mitigation and restoration, are used interchange-ably, especially when some field activities associatedwith each may be similar (such as revegetatingwith native plants). For BRMiS, “mitigation” and“restoration” are considered unrelated activities,and neither is equivalent to “remediation.”

Remediation, as defined here, is the act or process ofremoving or neutralizing contamination within thesoil, groundwater, or other environmental media.

Mitigation, as defined in this document, is theprocess of either preventing impacts to mitigableresources (through avoidance and minimization)or replacing lost resources (via rectification orcompensatory mitigation) if impact prevention isnot practicable.

Therefore, mitigation applies only to the disturbanceand/or loss of presently existing mitigable resourcesthat result from a project or action. Remediation ofa past practice waste site does not necessarilyimply a need for mitigation, unless there is a lossof an existing mitigable resource as a result of theremediation action. Defined as such, mitigationdoes not apply to resource loss-of-use that mayhave resulted from the past mission and wastemanagement practices at the Hanford Site. Resourceloss-of-use issues associated with past waste sitesshould be resolved through the CERCLA definedprocedures, including coordination with therespective Natural Resource Trustees.

Restoration, as defined here, is the process of creat-ing habitat value at a past practice waste site and isusually the final step in the remediation process.The created habitat may or may not resemble thehabitat present before construction of the wastesite. The type of habitat created will depend onsite-specific objectives and on future land-useconsiderations as developed by DOE, regulators,resource trustees, and other stakeholders. Thismitigation strategy is not intended to define orprovide guidance for these land-use considerations.

Figure 3 illustrates one example of the differencesbetween restoration and mitigation. This figureshows the portion of the area affected by a reme-diation action that potentially would requiremitigation and the portion that would fall underrestoration. The only portion that would be con-sidered for mitigation is the area containingmitigable habitat.

In this hypothetical example, the required mitiga-tion may include onsite rectification, such asreplacing shrubs, grasses, and forbs. The remainingportion of the affected area may require restoration(perhaps by planting native grasses), but notmitigation. In this example, mitigation via rectifi-cation would be more expensive than restorationbecause of the need to replace shrubs. Those costscould be greatly reduced or eliminated if theremedial action could be redesigned to minimizeimpact to the mitigable habitat.

As with any project or action on the Hanford Site,waste site remediation projects will be required tofollow the mitigation process and hierarchyoutlined in Section 1.3. These projects should beengineered to avoid and/or minimize impacts toexisting mitigable resources, and they will beexpected to rectify or compensate for any lossesthat are unavoidable.

Figure 4 depicts the mitigation process as itspecifically relates to remediation projects. Theecological compliance review for remediationprojects can be performed as part of the remedialinvestigation/feasibility study or remedial designphases. Performance of the ecological compliancereview relatively early in the remedial design willallow the project to be designed to have minimalimpacts on extant mitigable resources, andtherefore, will reduce or eliminate the need forfurther mitigation. Support activities such as theconstruction of monitoring wells or test pits mayrequire separate ecological compliance reviews.

Specific biological resources that will requireimpact assessment, monitoring, and mitigationare defined in BRMaP (DOE 2001a). Mitigableresources include plant and animal species ofconcern (state or federal endangered, threatened,candidate, or sensitive species), habitats for thesespecies, rare or unusual plant assemblages asdefined in the Washington Natural Heritage Plan(WDNR 1995), habitats with high native plant oranimal diversity, habitats lacking significantanthropogenic disturbance, and habitats speci-fically protected under state or federal regulations,such as jurisdictional wetlands.


Mitigable HabitatNon-Mitigable Habitat

Waste

Site

Remediation

Area of Impact

Portion of Impact Area

Potentially Subject

to Restoration

Portion of Impact Area

Potentially Subject

to Mitigation

Impact Area

Redesigned to

Minimize Impacts to

Mitigable Habitat

Waste Site

Remediation

Project

RI / FS Process

EcologicalCompliance

Review aids in

Avoidance &

Minimization ofImpacts

Perform

Remedial

Action

Were Extant

Mitigable Resources

Impacted?

Can Impactsbe Rectified

at Project

Site?

Restore WasteSite & Perform

Compensatory

Mitigation

Restore Waste Site

to Meet Land-UseObjectives

Restore Waste Siteand Rectify at

Project Site

Yes

Yes

No

No

BRMiS

ECAMP

Resto

rati

on

Remediation

Mit

igati

on

Restoration & Mitigation


Table 2 summarizes acts, regulations, and Execu-tive Orders that pertain to resource managementand mitigation on the Hanford Site. Some of theseprovide fairly explicit guidelines for when andhow mitigation is to be implemented (for instancethe requirement for a MAP as part of an Environ-mental Impact Statement [EIS] Record of Decision[ROD] under NEPA) while others (such as the

Federal Land Policy and Management Act) pro-vide a framework for the DOE’s stewardshipresponsibilities. Other acts and regulations thatmay affect specific types of activities on theHanford Site are listed in Table 3. Published poli-cies and guidelines of state and federal resourcemanagement agencies, which form the basis formuch of BRMiS, are summarized in Table 4.

National EnvironmentalPolicy Act (NEPA)

(42 U.S.C. 4321 et seq., CEQregulations at 40 CFR 1501 -1508; and DOE’s implementa-tion procedures at 10 CFR1021)

Relation to Mitigation and Resource ManagementDriver

• Requires preparation of NEPA documentation (categoricalexclusions, environmental assessments (EAs), and environmen-tal impact statements [EIS]) for federally funded projects.

• Requires preparation of a Mitigation Action Plan (MAP) toaddress mitigation commitments expressed in an ROD for anEIS.

• Mitigation commitments that are essential to render impacts ofa proposed action not significant are included in a Finding ofNo Significant Impact (FONSI) for an EA, and a MAP is pre-pared to address those commitments.

• If a cooperating agency objects to or has reservations about aproposed action on grounds of environmental impacts, thatagency must specify mitigation measures it considers necessary.

Endangered Species Act(ESA)

(16 U.S.C. 1531 et seq.)

• Requires protection of critical habitats for listed species.

• Requires federal agencies to evaluate actions to determine ifimpacts to protected species will occur, and if so, to prepare abiological assessment to determine if the action will jeopardizeprotected species. If the biological assessment concludes thatadverse impacts are likely to occur, then formal consultationwith the USFWS under Section 7 of the ESA is initiated.



Federal Land Policy andManagement Act

[43 U.S.C. 1701(a)(8)]

• Requires federal land be managed to protect the quality ofecological resources. Also identifies fish and wildlife habitatdevelopment as a principal federal land use.

Migratory Bird Treaty Act

(16 U.S.C. 703 et seq.)

• Makes destruction of nests or eggs, or hunting, pursuing, cap-turing, taking, or killing any migratory bird illegal.

• Compliance requires avoidance and/or minimization of im-pacts to nesting habitat, at least when the birds are present.

Comprehensive Environmen-tal Response, Compensation,and Liability Act (CERCLA)

(42 U.S.C. 9601 et seq.)

• Under certain circumstances, this Act provides for replacementor restoration of injured resources, or the services they provide,when impacts are a result of a CERCLA-regulated release.

Fish and Wildlife CoordinationAct

(16 U.S.C. 661 et seq.)

• Requires federal agencies, in consultation with the Secretary ofthe Interior, to give wildlife conservation equal considerationwith other values when planning activities that affect waterresources.

Sikes Act

(16 U.S.C. 670a-670o)

• Authorizes development and maintenance of fish and wildliferesources on Department of Defense, Department of Energy,National Aeronautics and Space Administration, U.S. ForestService, and Bureau of Land Management lands.

Clean Water Act

(33 U.S.C. 1251 et seq.)

• Requires a permit from the U.S. Army Corps of Engineers fordischarge of dredged material in wetlands. Appropriate andpracticable efforts to avoid or minimize adverse impacts arerequired for the permit.

• For unavoidable adverse impacts, appropriate and practicablemitigation is required; preference for onsite, in-kind mitigation.

Executive Order 11990

Protection of Wetlands

• Requires federal agencies to avoid or minimize the loss or deg-radation of wetlands on federal lands.

• DOE policy is to identify, evaluate, and as appropriate, imple-ment alternative actions that avoid or otherwise mitigate adverseimpacts (10 CFR 1022.3(d)).


Floodplain Management

• Federal agencies must account for floodplain management inwater or land use planning and avoid or minimize adverseeffects.


Mineral Leasing Act of 1920

(30 U.S.C. 185)

Relation to Mitigation and Resource ManagementAct

• Pertains to (among other matters) grants of right of ways forconstruction and operation of pipelines on federal lands, andpermits the Secretary of the Interior to issue guidelines dealingwith restoration of affected lands.

• This act could be pertinent if grants of right of ways for naturalgas pipelines are made on the outer areas on the Hanford Site.



Protection of Migratory Birds

• Directs each federal agency to develop a Memorandum ofUnderstanding (MOU) with the USFWS to promote conserva-tion of migratory birds.

• Among other things, directs agencies to “restore and enhancethe habitat of migratory birds” and to “prevent or abate thepollution or detrimental alteration of the environment for thebenefit of migratory birds, as practicable.”


Invasive Species

• Restricts introduction of exotic species into federally owned ormanaged lands or waters.

• Requires monitoring and control of invasive species and resto-ration of native species.

• Revoked the similar E.O. 11987 “Exotic Organisms.”


SummaryAgency

U.S. Fish and Wildlife ServiceMitigation Policy

(46 FR 7644-7663)

• Provides mitigation recommendations based on habitat value;acre for acre replacement not necessarily recommended.

• Establishes four “Resource Categories” to identify areas of highand low habitat values for important species.

• Follows the Council on Environmental Quality (CEQ) guide-lines for mitigation: avoid the impact, minimize the impact,rectify the impact, reduce the impact over time, and finally,compensate for the impact.

Bureau of Land Management(BLM) Restoration/Mitiga-tion Plans and Guidelines

• Details management guidelines that direct BLM to includehabitat management plans in the project planning process.

• Requires monitoring of habitat management following projectcompletion to ensure management goals are being met.

• Directs BLM to expend maximum effort toward carrying outprograms that will restore habitat and populations “to the pointthat the provisions of the Endangered Species Act are no longernecessary.”

Washington Department ofFish and Wildlife (WDFW)Mitigation Policy

POL-M5002; January 1999

• Follows CEQ guidelines for mitigation.

• States that mitigation should ensure no net loss of habitat orpopulations.

• Provides direction for use of in-kind/out-of-kind, onsite/offsitemitigation. Onsite, in-kind is highest priority. All out-of-kindmust be approved case by case.

• States that Priority Habitats and Species, defined by the WDFW’sPriority Habitats and Species Program, receive additional con-sideration; in some cases, preservation of Priority Habitats canbe considered mitigation.

• Includes guidance for documenting terms of mitigation.


Effective implementation of BRMiS and BRMaPrequires that the roles and responsibilities be welldefined for DOE-RL and each of its contractors.Figure 5 depicts the roles and responsibilities foreach organization or group described in thefollowing sections and the overall relationships.

The DOE has numerous responsibilities concern-ing biological resource management in general andmitigation in particular. Specific roles are assignedto various offices within DOE. As part of its cross-programmatic responsibilities DOE will:

• integrate biological resource management goalsand administrative procedures into the day-to-day and broader planning activities of facilitiesor programs to ensure that adverse impacts tobiological resources are avoided or minimizedwhen practicable

• as a natural resource steward, mitigate, viaprevention or replacement, adverse impacts tonatural resources

• as a lead response agency, conduct site activ-ities (e.g., remediation or site developmentprojects) in a cost-effective manner whileavoiding or minimizing adverse impacts tonatural resources

• as a CERCLA natural resource trustee, coordi-nate with other natural resource trustees andappropriate resource agencies with respect tonatural resource issues associated with CERCLAactivities in an open and cooperative manner.

In addition to the broader DOE responsibilities,each program manager will apply the provisionsof these policies to each site, facility, or program

under his/her responsibility. This will ensure thatbiological resource protection measures areapplied consistently site-wide. Each programmanager will:

• identify biological resource issues in the earlyphases of both remedial actions and newfacility projects

• identify to the Division of Closure (CLO) earlyin the project planning process any potentialadverse impacts to mitigable resources thatmay result from program activities

• incorporate into project plans and implementrecommendations to avoid and minimizeadverse impacts to biological resources, andrectify and/or compensate for unavoidableimpacts, as required by the ecologicalcompliance review and BRMiS

• budget for mitigation requirements early in theproject planning process.

The Assistant Manager for Infrastructure andClosure (AMC), through the Division of Closure(CLO) will:

• act as the focal point for the development andcoordination of site- and program-wide biologi-cal resources mitigation policies and guidance

• be responsible for ecological assessments andimpact management, including development ofrecommendations for avoidance and/or mini-mization of project impacts

• be responsible for mitigation reporting andmonitoring of mitigation areas or a mitigationbank, including (when applicable) develop-ment of an accounting system for both bankcredits (resulting from habitat improvementactions) and for bank debits (resulting from


adverse impacts to biological resources thatrequire compensatory mitigation)

• develop models needed to quantify habitatvalue losses due to project impacts and habitatvalue gains resulting from improvement actions.

• identify and designate areas that are ecologic-ally sensitive, or possess unique habitats, anddesignate them as such in land use plans andmaps

• identify potential areas to be used for a miti-gation bank or for compensatory mitigationareas

All Hanford Site contractors will incorporatebiological resource values into the early phases ofproject planning. This includes obtaining ecological

Implementation


assessments for all projects that require an ecologi-cal compliance review, as defined in ECAMP, andincorporating any avoidance and minimizationrecommendations that may be included in theproject ecological compliance review.

Contractor personnel will also work with boththeir DOE-RL program representatives and theAMC/CLO to budget for and implement anyrectification or compensatory mitigation forunavoidable impacts to mitigable resources. Thismay include onsite habitat improvement measureswhen the project is completed, participation in asite-wide mitigation bank, or other forms of com-pensatory mitigation if appropriate.

The PNNL is responsible for conducting mostecological assessments as described in ECAMP, theEnvironmental Restoration Contractor (ERC)/River Corridor Contractor (RCC) performs some

ecological assessments for environmental remedia-tion projects. Recommendations for the avoidanceand minimization of project impacts will beincluded as part of the project review process.PNNL, in coordination with other site contractorsand resource agencies, also will be responsible fordeveloping appropriate models to determine miti-gation threshold levels, habitat replacement ratios,and the quantification of rectification and compen-satory mitigation requirements and success.

PNNL will be responsible for monitoring mitiga-tion areas and for the preparation of annual reportsconcerning mitigation for most projects. The ERC/RCC may perform these functions in support itsmitigation actions.

All other Site contractors will be responsible forimplementing habitat improvements within miti-gation banks and for the continued operation andmaintenance of the mitigation banks.


Virtually all areas on the Hanford Site, includingindustrial areas, constitute habitat for some typesof plants and wildlife. However, it is not practical,possible, or even desirable to mitigate for any andall changes to the current habitat base. The BRMiSis designed to direct adverse impacts away fromareas of significant habitat value and into areas oflower habitat value, or most preferably, into areasthat already have been considerably disturbed.The two most obvious benefits from avoidingadverse impacts are reduced costs to projects andpreservation of highly valued biological resourcesand habitats.

Areas with high wildlife usage, as well as undis-turbed or rare habitat characteristics, generally willrequire mitigation of impacts. Areas of low habitatvalue may have no mitigation requirements. Thissection provides guidelines to determine types andlevels of impacts requiring mitigation.

It is the policy of DOE-RL, through BRMiS, todetermine mitigation requirements on the basis ofimpacts to resource or habitat value rather thanstrictly on the size of the impacted area. This policyencourages projects to be located in areas with lowextant habitat value because the mitigation require-ments associated with these areas will be less thanthe requirements associated with the disturbanceof the same acreage of high-quality habitat.

Habitat value is defined as the suitability of an areato support selected animal and/or plant species.Habitat value is a function of both the speciesselected for evaluation and the habitat character-

istics of the site, such as the presence and percent-age cover of key plant species. Evaluation specieswill include species identified in BRMaP as beingindicative of a particular habitat type.

The USFWS habitat evaluation procedures useHabitat Suitability Index (HSI) models to quantifyhabitat value for evaluation species (USFWS 1980).Habitat Suitability Index models provide an indexof “suitability” that ranges from 0 to 1 (USFWS1981). An index of 0 indicates an area is completelyunusable for the evaluation species; an index of 1indicates optimal habitat conditions. An HSI canbe estimated for an area regardless of whether theevaluation species actually occupies or uses theevaluated area; however, the USFWS prefers usingspecies with at least a strong potential of beingpresent on a site. The currency of the HabitatEvaluation Procedure (HEP) is the Habitat Unit(HU), which is a measure of both the quality andquantity of habitat. Specifically:

Habitat units = quality (HSI value) x quantity (areain acres or hectares)

Therefore, 1 HU = 1 (unit) of prime habitat interms of the performance measures selected for theevaluation species.

Habitat evaluation methods require:

• selection of evaluation species that will serve asrepresentative indicators of overall habitatvalue

• identification of performance measures for theevaluation species (such as density, home rangesize, or productivity)


• formulation/adaptation of quantitative modelsthat allow translation of habitat variables intomeasures of habitat suitability based onperformance measures for the evaluationspecies.

For the Hanford Site, HSI models may be developedfor each evaluation species pertinent to key Hanfordhabitats. Habitat characteristics that representelements used by an evaluation species will beincluded in the model. These models will form thebasis for determining a mitigation threshold that,when exceeded, triggers the need for mitigation.Additional habitat features such as shape, size, anddegree of isolation or connectedness to similarhabitats that relate directly to habitat functionalityfor evaluation species will be incorporated into amitigation threshold level determination.

Criteria that do not relate directly to habitat func-tionality for evaluation species, but are importantin deriving habitat value and mitigation thres-holds, might include:

• habitat scarcity on a local and regional scale

• ease of habitat replacement (throughamendment, reclamation, or creation).

Likely evaluation species for sagebrush-steppehabitat are loggerhead shrikes (Lanius ludovicianus),sage sparrows (Amphispiza belli), and black-tailedjackrabbits (Lepus californicus) because of theirregulatory status and habitat requirements. Otherspecies may be added as the process develops.Additional mitigable resources are identified inBRMaP, including pristine areas with high per-centages of native plant cover, habitats that arelocally rare (such as dunes and lithosols), andareas dedicated to ecological research such as theFitzner/Eberhardt Arid Lands Ecology (ALE)Reserve.

The HEP methodology provides two types ofhabitat comparisons: 1) the relative value of differ-ent areas at the same point in time, and 2) therelative value of the same area at different pointsin time. Combining these two types of compari-sons enables equitable trade-offs to be madebetween the value of habitats lost to developmentand the value of replacement habitats.

Figure 6 illustrates one example of this trade-offcalculation. Point A indicates the total HUs at aproject site when the project is initiated. Whenimpacts occur, the number of HUs at that site

drops to point B. If onsite rectification takes place,the number of HUs increases over time to point C.If onsite rectification is not (or cannot be) performed,the total HUs at the project site will remain atpoint B. Integration over time produces the quantityof HUs lost because of the project and for whichcompensatory mitigation may be appropriate.Rectification reduces the total number of HUs lostover time. At an offsite mitigation area, the pre-existing quantity of HUs is represented by point D.

If improvements are made at the mitigation areato compensate for impacts at the project site, thequantity of HUs will increase to point F. Integra-tion over time will provide an estimate of the HUsgained at the mitigation area. However, the miti-gation area may be expected to experience anatural increase in habitat quality (to point E)over the same period of time, even without thecompensatory actions.

The amount of resource improvement thatnaturally would have occurred at the mitigationarea without compensatory improvements shouldnot be included in the calculation of total resourcegain. Project mitigation requirements are metwhen the number of HUs gained through thecombination of rectification and compensationequals the quantity lost due to project impacts.

Impact thresholds will depend on the point in themitigation hierarchy at which a project is, as wellas the particular resource(s) that may be impacted.In the first two steps of the mitigation process (i.e.,avoidance and minimization) no set thresholdlevel exists if managed resources are present. Allprojects are expected to avoid and minimizeimpacts to the greatest extent possible and shouldweight these considerations equally with otherproject siting criteria. Likewise, all projects areexpected to rectify impacts at the project site to thegreatest extent practicable.

Some resources, such as jurisdictional wetlands,have no mitigation threshold level and any impactto these resources will require mitigation. Others,such as shrub-steppe, may require compensatorymitigation if the impact (after avoidance, minimi-zation, and onsite rectification) is determined toreduce the habitat value for wildlife.


Reduction in habitat value will be quantified witha HSI, which will determine the area of impactedhabitat needed to support a breeding pair of theevaluation species (or an individual territory, asappropriate). When the area of impact displacesone or more breeding pairs or individuals, asappropriate, of the evaluation species, that levelshall be considered the threshold that triggersmitigation. For a specific habitat, such as shrub-steppe, this approach would account for impactsto both mature and recovering areas that have ahabitat value greater than zero for the evaluationspecies.

Mature shrub-steppe has thus far been the impetusfor and focus of the development of mitigationguidelines for the Hanford Site. This is due to itsrelative scarcity in the region, its importance tovarious wildlife species of concern, and its desig-nation as a priority habitat by WDFW. Noss et al.

(1995) classified ungrazed sagebrush steppe in theIntermountain West as a critically endangeredecosystem that has experienced greater than a 98%decline since European settlement. Evaluationspecies were tentatively selected based on theirassociation with this habitat. Although this habitatis a current priority for mitigation, other habitatsand species may be considered mitigable resourcesunder BRMaP. The selection of other evaluationspecies may be required to assess impacts to otherhabitat types.

Site-wide habitat deterioration from causes otherthan projects, such as range fires, may result indeclining populations of evaluation species. Ifthese levels fall below critical population levels setfor the Hanford Site (as prescribed by BRMaP), themitigation threshold guidelines may be revised.


The preferred method to determine mitigationthreshold levels, as described in Section 4.3,requires the development of Hanford-specificmodels of habitat usage by the evaluation species.These models are not currently available. Untilsuch models are developed, land-area-basedinterim guidelines provided in Table 5 will befollowed. These interim guidelines were developedbased on the estimated minimum home range sizeof one potential evaluation species (sage sparrow)and current Hanford Site disturbance and land-usepatterns.

Based on data presented in Fitzner (2000), theestimated minimum sage sparrow home range sizeis 0.5 ha of mature sagebrush steppe. This agreeswith an estimate based on body weight (Calder1984). This interim threshold applies only to areaswith mature sagebrush, and not to areas of lowerquality habitat. For these interim guidelines, mature

sagebrush steppe habitat has at least 10% cover ofa climax shrub species such as big sagebrush(Artemisia tridentata) or bitterbrush (Purshiatridentata), average shrub height of at least 0.5 m,and native species in the understory.

Different interim mitigation threshold levels are setfor different regions of the Hanford Site (Table 5).Figure 7 shows different threshold regions in the200 Area Plateau. Specific plant communitiesaffected by these guidelines are provided in BRMaP.

Table 5 also provides both single-site and project-cumulative mitigation threshold levels. This isbecause a single portion of a project (such as onewell site) may have minimal impact and be belowthe threshold level, but the cumulative impact ofan entire project (for instance 20 well sites) may bedetrimental. These guidelines are an attempt tobalance the effects of habitat fragmentation thatcould result from numerous small disturbanceswith the fact that each individual disturbance mayhave nominal impact.

IndividualSite

ProjectCumulative

Region 600 Area 200 AreasCorridor

200-East: southhalf; 200-West:

northeastquarter

All other sites within 200, 300,and 400 Area fences, 100 Area

perimeter roads, and 1100 AreaIndustrial Sites

0.5

2.5

1

5

5

10

No mitigation of habitat lossrequired other than avoidanceand minimization


NNNN


Implementing BRMiS is a necessary component ofbiological resources management on the HanfordSite. This strategy can be implemented in a mannerthat allows mitigation goals to be met withoutsignificant effects on budgets or schedules.

Implementation follows the order of mitigationpriorities as presented in Table 1. Impacts shouldbe avoided or minimized, if possible, and rectifiedor compensated only if avoidance and minimiza-tion do not satisfy all project mitigation needs. Ifcompensatory mitigation is required away fromthe project site, mitigation requirements should bemet through participation in a mitigation bank, asdescribed in Section 5.4 of this document.

The goals of the Hanford Site biological mitigationstrategy are to:

• prevent habitat value loss through avoidanceand minimization

• provide timely rectification or compensationfor habitat value lost through Site developmentor cleanup activities

• ensure no net loss of habitat value for mitigableresources

• ensure no net loss of key habitats such asnatural wetlands and locally rare or pristinecommunities

• minimize time lags between the loss of habitatvalue and its replacement

• enhance the function of habitat on a landscapescale (for example, minimize fragmentationand maximize connectivity)

• address biological resource impactscomprehensively and cost effectively.

Mitigation should be identified and implementedas early in the project as possible. Preferably, miti-gation needs would be identified during the impactmanagement phase of the ecological complianceassessment process. Impact management shouldoccur during the site selection process to addressthe avoidance and minimization steps of themitigation process, thereby reducing the need forrectification and/or compensation. Additionalmitigation needs may be identified later in theproject via the ecological compliance review asdescribed in ECAMP (DOE 1995a).

Mitigation at the project site includes avoiding,minimizing, or rectifying project impacts (seeTable 1). Project impacts can be avoided orminimized by following such steps as:

• implementing non-disturbing alternatives

• locating a project at a less ecologicallydamaging site

• reducing project land-use requirements

• scheduling project activities to minimizedisturbance to biological resources of concern.

Each project should pursue the avoidance andminimization steps of the mitigation hierarchyfirst. Avoidance and minimization actions arelikely to be less costly, have less potential to


adversely impact project schedules, and cause lessinjury to biological resources than actions that relyon habitat improvement. These two types of miti-gation actions are addressed more fully in ECAMP(DOE 1995a).

If ecological disturbance still results after avoid-ance and minimization, mitigation should occur byrectifying impacts at the project site. Aspects ofrectification are also discussed in Section 5.6.1.

Mitigation banking is the establishment of habitatfor managed resources (or the resources them-selves) in areas other than at the impact site tocompensate for unavoidable habitat value lossesexpected to result from future project development.Use of a centralized bank for compensatory miti-gation will simplify the mitigation process forsmall projects because the goals, methodologies,and locations for compensatory mitigation will bepre-defined. A small project will not be required todesign and engineer its own mitigation actions,but would simply pay into the established systemor bank. A bank enables the mitigation requirementsfor numerous projects to be coordinated andconducted in a manner that creates the greatestoverall improvement in habitat value whilereducing costs because of the economy of scale.

The degree to which compensatory mitigation iscoordinated site-wide can range from a project-by-project approach to complete coordination withpre-emptive habitat value replacement. Four basiclevels of coordination can be identified as follow:

1. Each project (or program) identifies itscompensatory mitigation areas, plans andimplements its own habitat improvements,and is responsible for maintaining andmonitoring the mitigation areas.

2. One or more common mitigation areas areidentified, but each project continues to planand implement habitat improvements withinthat area, and is responsible for the continuedmonitoring and maintenance of its portion ofthe mitigation area.

3. A pseudo-mitigation bank is created with oneor more common mitigation areas. Habitatimprovements are coordinated by the bank

managers using standardized implementingprocedures. Maintenance and monitoring ofthe mitigation areas are performed by the bankmanagers. Under a pseudo-bank, credits arecreated (e.g., through habitat improvement) asa response to project needs, and usually suchcredits are created after the losses already haveoccurred.

4. A true mitigation bank is created. This isessentially the same as a pseudo-bank, exceptthat credits are created in anticipation of futureproject needs and before the project-inducedlosses occur.

Use of a common mitigation area will save timeand money because siting decisions only need tobe made once. Use of a banking system savesadditional money because projects will not berequired to engineer the habitat improvements orset up individual sub-contracts to perform theimprovements. Under a bank system, each projectwould simply pay into a common pool operatedby the bank managers (tentatively led by CLO)who would coordinate the habitat improvementsfor all projects. Use of a true mitigation bankwould ultimately be the most cost effective, but itwould require that non-project specific “seedmoney” be identified and appropriated to createthe initial bank credits before they are needed byprojects.

Advantages of mitigation banking include thefollowing:

• provides overall coordination of site mitigation

• eliminates the project-by-project learning curve

• reduces the time required for preparation ofNEPA documents

• provides consistency in mitigation practices

• eliminates extended project durations requiredfor mitigation

• allows projects to adequately budget formitigation

• ensures that mitigation will be performed byexperienced personnel

• ensures impacts of a similar nature are treatedin a similar but comprehensive manner.

Mitigation banking provides a means both tominimize the risk to resource health and survival


posed by future projects and to perform habitatimprovement and monitoring in a cost-efficientmanner. Mitigation banking has been developedfor addressing wetland impacts (e.g., Castelle et al.1992a), but has been less well defined for impactsin other areas. It is recognized as a potentialcomponent of mitigation by both the USFWS (46FR 7644, USFWS 1988) and the WDFW (1999).

Mitigation banking requires that the followingcomponents be identified and established:

• bank objectives and currency

• bank site(s), including necessary site protectionand controls

• policy for bank operation, including payments,construction, use of credits and debits, andbank management responsibilities

• funds and schedule for monitoring, correctiveactions, and reporting on bank operations.

The objectives for mitigation bank(s) on theHanford Site are to:

• consolidate numerous small mitigation projectsinto one or a few sites that can meet broaderobjectives requiring a landscape-level approach

• provide timely compensation for habitat lossresulting from Hanford Site activities

• ensure that lost habitat value is adequatelycompensated

• maintain mitigable resources within limits ofabundance and temporal stability conducive tosurvival and health of the resources

• preserve the bank’s mitigated resourcesthrough long-term monitoring andmanagement.

Specific goals must be specified for each type ofbank created. Based on expected impacts atHanford over the next 5 to 10 years, banks maybe needed for the following habitats:

• mature sagebrush-steppe

• bitterbrush-steppe

• sagebrush-hopsage steppe.

These habitats provide the basic elements requiredfor many wildlife resources identified as foci formanagement concern under BRMaP. Cumulativeimpacts within these habitats are expected to rangefrom moderate to extensive.

Currency for the banks will consist of units ofhabitat value. Habitat value is defined on the basisof the resources affected by the habitat improvementwithin the bank. Habitat evaluation methods, thus,are required to quantify habitat value, both at theimpact site and at the bank. Habitat improvementsat the bank are intended to increase habitat valueof the bank site, which constitutes the total creditin the bank available for offsetting project losses.

Ultimately, a fixed dollar fee per hectare, dependenton habitat quality, can be assigned. This fee cannotbe determined until the HSI models are availableto assess quality, and experience in habitat improve-ment is gained via field applications. A fixed feewill simplify budget planning and will enableplanners to assess both ecological and economictrade-offs when making siting decisions.

Some criteria that affect bank siting are listedbelow. Section 6.0 provides detailed criteria forsiting a mitigation area or bank.

• The site(s) should be of sufficient size to meetthe expected need (i.e., the anticipated extentand value of the resources to be impacted overthe next 5 to 10 years). Small and isolated sitesselected for mitigation of individual smallprojects may have limited habitat value. Byestablishing a larger bank to satisfy the mitiga-tion needs of a number of projects, moreecologically valuable areas can be developedand managed. Also, land management, moni-toring, and evaluation of mitigation complianceand success are more efficient with a largermitigation bank.

• A large portion of the site(s) currently shouldbe of relatively low value but capable of suc-cessful improvement, thereby allowing forincreased use by the managed resources afterhabitat improvements are complete.

• The site(s) should be set within a favorablehabitat context, i.e., must provide functionalityat a larger scale than the bank itself.


• The site(s) should be near existing infrastruc-ture needed to support the habitat improve-ment efforts (e.g., water, roadways).

• The site(s) should not be adversely affected byexisting or proposed land uses.

The bank should be created early to take advan-tage of mitigation opportunities that may disappearover time. As lands become committed for otheruses, it becomes more difficult to locate the bankarea from a landscape perspective.

Banks sites will be administratively protected. Themitigation bank site(s) will be designated as LevelIV (most restrictive category) in BRMaP and theHCP-EIS. Functionally, this will prevent disturbanceof the site(s) for as long as DOE maintains admin-istrative control of the area. If deed restrictions areinstituted, site protection could continue long afterDOE’s mission is completed. Protecting banksite(s) in this way will assist DOE and projects innot incurring significant costs. At a minimum,bank site(s) must be protected for the life of theparticipating projects or until all the habitat valuelost as a result of participating projects is replaced,whichever is longer.

Bank credits are normally given only for improve-ments on lands under the direct control of thebank sponsor. However, lands that are managedby or released to other federal agencies may beeligible for use as bank sites if the receiving partyagrees that the bank site will be managed for itsresource values. Bank withdrawals should bebased on habitat value replacement, not acreage orcost for habitat improvement, land purchase, ormanagement.

The preferred location for habitat replacement isthe site being impacted; however, situations existwhere this option is infeasible or would result insubstantial time lags in the recovery of lost resourcevalues. For example, converting wildlife habitat toan industrial site severely limits the options foronsite rectification; similarly, removal of habitat forthe purposes of waste burial will adversely impactthe biological resources during the interval betweensite clearing and onsite rectification. In these situa-tions, compensatory mitigation away from theproject site can be used to ensure maintenance ofresources at the prescribed management levels.

When compensatory mitigation is required, miti-gation banking is preferable to an uncoordinatedproject-by-project approach. Operation of the bankwill reduce the net loss of total habitat value on asite-wide basis. Because habitat value is used asthe currency for mitigation, credits to and debitsfrom the bank must be for “in-kind” rather than“out-of-kind” mitigation.

Mitigation banking is not an alternative to avoid-ing or minimizing habitat value losses or forperforming onsite rectification that would recoverhabitat value in a timely manner. Mitigationbanking should be used only when adverseimpacts are unavoidable and all reasonable meansof avoidance, minimization, and rectification havebeen used.

Projects can pay into the bank at any time, but thepreferred method of bank operation is to initiatehabitat improvements before use of the credits.This will help ensure that levels of the affectedbiological resources do not decline between thetime of project impact and the time when suitableimproved habitat is available to support theresources. Project budgets should be developedto allow credits to be purchased the early in theproject life (the first year of the project for projectsof 3 years or less).

The bank will be managed by DOE-RL, withspecific operational responsibility assigned to anappropriate division. CLO will provide short- andlong-term management of the banking program.Short-term management responsibilities includedeveloping guidance for operation and habitatimprovements within the banking site(s), coordi-nating habitat improvements within the bank,monitoring the improvements and evaluatingimprovement methods, and managing credits anddebits. Long-term management responsibilitiesinclude monitoring, reporting, and determiningnecessary corrective actions. CLO also will ensurethat mitigation bank sites are clearly identified onHanford Site land-use planning maps.

Habitat improvements within the bank will betemporally and spatially coordinated to minimizehabitat fragmentation and maximize benefits incontext of the surrounding landscape.

Bank maintenance may include:

• weed control

• minimizing depredation of transplants


• irrigation

• fire control and prevention

• modifying banking guidance, as necessary, torespond to changes in management needs andhabitat improvement methodologies.

Bank corrective actions may include:

• replanting if mortality causes habitat values tofall below target levels

• designing and implementing new habitatimprovement methodologies.

Monitoring is necessary to ensure that the bankmeets its resource maintenance and improvementgoals, that it can respond to contingent needs andevents, and that it functions in a cost-efficientmanner. Specific monitoring needs may includethe following:

• plant species composition, abundance, andspatial pattern

• shrub survival and growth

• soil microbial activity (nitrification anddecomposition)

• wildlife usage

• sources of plant mortality

• trends of wildlife use and landscape patternson and near the Hanford Site.

Reporting should occur annually and provideinformation summaries that:

• track the progress of the banking programagainst its goals

• track the status of the bank with regard tocredits and debits

• provide a means for resource agencies, naturalresource trustees, and other outside groups toassess the relative success of the program

• provide the information necessary to allowDOE-RL to alter its operational guidance forthe bank to better meet its objectives

• provide information to assist outside agenciesin developing their own banking programs.

Levels of mitigation range from impact avoidanceto compensation (Table 1). Means to accomplishimpact avoidance or minimization are identifiedthrough the ecological compliance review processbefore siting and implementation of a proposedproject. These two types of mitigation are alwayspreferred over rectification and compensationbecause they avoid the expense of habitat replace-ment and minimize the risk of causing a decline inbiological resources of concern. Mitigation require-ments for a particular project may include a com-bination of mitigation levels.

Rectifying or compensating for impacts requiressome level of habitat improvement. Habitatimprovements may be of three general types:amendment, reclamation, and creation. Amend-ment is the improvement in the function/value ofan existing habitat; reclamation is the improvementof the value or function of a degraded habitat;creation is the establishment of a functioninghabitat at a site where none currently exists.Examples of each are given in Table 6.

All habitat improvement efforts risk failure, andthis risk increases in proportion to the degree ofhabitat manipulation attempted (Figure 8). Thelowest risk involves protecting existing habitatsthat contain the appropriate biological resources,and making minor improvements to existinghabitats to ensure no net loss of the resources. Thehighest risk involves creating habitat. Rectificationof impacts (e.g., replacing habitat in excavatedareas) will generally involve habitat creation.

A replacement ratio is the ratio of the number ofhabitat units produced at a compensation site tothe number lost at the site of adverse impacts.Sometimes this may translate as the area overwhich mitigation measures are applied to the areareceiving adverse impacts (assuming equivalenthabitat value at each site). Alternatively, it can bethe ratio of the improved habitat value at themitigation area to the habitat value at an impactedsite (assuming the same land area for each site)(see Figure 9). A combination of area and qualityconsiderations can also be used.


Amendment

ExampleManipulation Level

Establishing large-statured sagebrush within a naturally regeneratingburn area to provide nesting/perching habitat for loggerhead shrikes andsage sparrows.

Reclamation Establishing shrub-steppe plants in an abandoned old field cheatgrasscommunity.

Creation Establishing shrub-steppe plants in a former gravel pit.

Mitigation LevelMitigation Level ConstraintsConstraints

Disturbed

Area &

Quality

Replacement

Ratio Land-Based Quality-Basedx = or =

or =

or =

or =

or =

x

x

x

x

4:1

3:1

2:1

1:1

Initial Replacement Ratio:

=

=

=

=


The replacement ratio for protected plant specieswill be 1:1 (individual plants). Replacement ratiosfor impacts to riparian or wetland habitats willcomply with Washington Department of Ecology(Ecology) requirements for wetland mitigation [2:1on an area basis with equivalent plant speciesdensity (Castelle et al. 1992b)]. Replacement ratiosfor other habitats require a definition of habitatvalue, which in turn require development of habitatsuitability models for the evaluation species selectedfor that habitat (see Section 4.2). These models arebeing developed for shrub-steppe habitats. Whenthese models are completed, replacement ratioswill be based on quantitative habitat value evalua-tions at an impacted area.

To meet the desired mitigation endpoints, replace-ment ratios should be set with both the expectedfailure rate inherent in habitat improvementactivities and the time lag for development of thereplacement resources taken into account. Failurerate-based replacement ratios have been used indefining wetlands mitigation by Ecology (Castelleet al. 1992b).

The best source of information on failure rates isHanford Site experience. Since the mid-1990s therehave been a number of projects that have includedplanting sagebrush plants (Table 7). Survival ratesvaried considerably between projects and alsowith the length of the monitoring period. Forseveral projects, notably the mitigation for theEnvironmental Restoration Disposal Facility, W-112, and W-058, the mitigation sites were lost in the24 Command fire in June 2000; therefore, furthermonitoring is not available.

Many projects had sagebrush survival rates thatwere greater than 60%, at least over the first year,but a significant number had survival rates consid-erably lower. Additionally, several projects reportedsignificant variation in survival among individualmonitoring transects. For instance, Sackschewsky(1999) reported that survival of tublings along16 individual transects at the W-058 mitigationarea ranged between 19% and 88%. Durham andSackschewsky (2002) reported that survival of bareroot plants that were planted in 2000 ranged from7% to 91% after two growing seasons, dependingon soil type and plant community conditions.

There are much less data available concerningtransplant survival of other shrub species on theHanford Site. Gano et al. (1999) reported nearly100% mortality for a small planting of bitterbrush

at the 300-FF-1 site. Additional plants were plantedin 2001, and Johnson (2001) reported 55% survivalover the first growing season. Brandt et al. (1991a)reported a first year survival rate of 59% forbitterbrush at Basalt Waste Isolation Projectborehole sites. Brandt et al. (1991a) reported firstyear survival rates for hopsage (38%), gray rabbit-brush (79%), and green rabbitbrush (48%).

There is limited information concerning nativegrasses. Brandt et al. (1991a, 1991b) reported that60% of the severely disturbed sites that had receivedunderstory amendment treatments using nativegrasses failed to meet percentage cover goals fornative grasses because of mortality of seededgrasses. The grass mortality rate continued at 60%into the next year, but declined to near zero by thethird year (Brandt et al. 1991a, 1993).

However, it normally takes several years for grassesto become established and contribute significantlyto overall plant cover, and in some cases, there isvery little of the planted grasses visible during thefirst one or two years. McLendon and Redente(1997) suggest that no specific level of plantedspecies cover should be used as an evaluationcriteria during the first 2 to 5 years after planting,but total cover (i.e., all species) can be used as thecriteria. Hanford Site environmental restorationhas resulted in the opportunity to re-establishnative vegetation in a variety of different settingsas waste sites are cleaned up. Some of theseplantings have been monitored for several years(Johnson 2001). Most of these plantings appear tobe successful, although the variation in plantingconditions and restoration goals does not allow forbroader conclusions to be drawn at this time.

With additional field data and experience, thefailure rate portion of the replacement ratio deter-mination may be either increased or decreasedaccordingly. Based on the available data, it isreasonable to assume at least 50% survival rate ofplanted shrubs. Thus, approximately twice thenumber of shrubs desired at the end-state shouldbe planted—suggesting a 2:1 replacement ratio.

However, the failure rate is not the only considera-tion in setting a replacement ratio. In arid terres-trial systems, there will usually be a time lag,perhaps measured in decades, between when themitigation actions are performed and when themitigation area becomes usable habitat. Therefore,the replacement ratio should be set at a point thatwill allow the habitat value to be replaced in a


BWIP Restoration

Plant MaterialProject

BarerootALE sagebrushplanting

Survival Reference

58% after 1 year Brandt et al. (1991a)Tublings

80% after 4 years T. Feldpausch andJ. L. Downs (unpub.)

Bareroot

Tublings

Mixed bareroot and tublings

ERDF Mitigation 87% after 1 year

66% after 1 year

62% after 1 year

Johnson et al. (2000)

Salvage plants (Aug. planting)

Salvage plants (Oct. planting)

Wahluke Slope 5% after 1 year

78% after 5 years

Gano et al. (1999)

Johnson (2001)

Container grownplants

300-FF-1 42% after 4 years Johnson (2001)

Tublings200-ZP-1 pipeline 29% after 2 years Gano et al. (1999)

Tublings216-A-25 Gano et al. (1999)65% after 2 years

Tublings (imported topsoil)

Tublings (cobble substrate)

116-C-1 Johnson (2001)66% after 3 years

94% after 3 years

Tublings116-B-5 Johnson (2001)99% after 1growing season

Mature shrub transplants

Tublings (Feb. 97 planting)

Tublings (Nov. 97 planting)

W-058 Mitigation Sackschewsky (1999)91% after 4 years

76% after 3 years

49% after 2 years

TublingsW-112 Mitigation R. Roos and A. R.Johnson (unpub.)

88% after 2 years

Tublings (1999 planting)

Bareroot (1999 planting)

Tublings (2000 planting)

Bareroot (2000 planting)

W-519 Mitigation Durham andSackschewsky (2002)

37% after 3 years

45% after 3 years

53% after 2 years

62% after 2 years


reasonable period of time, even if it may ultimatelyresult in a larger number of habitat units decadeslater (see Figure 6). To account for both the failurerate and the replacement time lag the replacementratio should be set higher than a simple considera-tion of failure rates would suggest. Developmentof quantitative habitat evaluation models (seeSection 4.2) will allow for the calculation ofecologically meaningful replacement ratios.

The knowledge base concerning both failure ratesand the time required for habitat valuereplacement will be augmented as this mitigationstrategy is implemented, new techniques forhabitat improvement are developed and tested,and as habitat evaluation models are developed.Recommendations for replacement ratios will beupdated based on experience and technologicalimprovements.

Until quantitative models are developed that willallow for assessment of habitat loss and habitatimprovement, interim mitigation ratios will beused.

For compensatory mitigation of shrub-steppehabitats, the ratio will be 3:1 based on area. Forrectification at the site of impact, the ratio will be1:1, as long as the replacement can commencewithin two planting seasons of the initial impact.If the rectification cannot be performed withintwo planting seasons, the 3:1 ratio will apply,and compensatory mitigation will be required.

An exception applies to the portions of the200 Areas with a mitigation threshold of 5 ha (i.e.,the northeast corner of the 200-West Area and thesouthern portion of the 200-East Area; see Table 5and Figure 7. In these areas, the replacement ratiowill be 1:1, and no distinction is made betweenrectification and compensation. A project mayreplace the resources at the point of impact ifappropriate or stabilize the soil surface and replacethe lost resources at a separate mitigation area. Thesecond option would allow another project to usethe disturbed area at a later date without incurringa mitigation commitment.

As stated previously, the replacement ratio for rareplants will be 1:1 based on individuals, and theratio for wetland or riparian habitats will be 2:1based on area.

Successful planning and budgeting for mitigationcommitments require that the level of effort (i.e.,the number of transplanted shrubs, tublings)needed to achieve the mitigation goals be quanti-fied in the early stages of project planning. Ideally,the level of effort is determined based on thehabitat value at the project site and the level ofimprovement possible through rectification orthrough compensation at a mitigation area.Quantitative habitat value models are requiredfor these calculations.

Until such models are available, projects thatdisturb late-successional sagebrush steppe shouldplan for replacement mitigation using standardreplacement units. Replacement units for otherhabitats will be developed as needed.

Therefore, a project that is replacing habitat viarectification at a ratio of 1:1 should plan for 1replacement unit/ha disturbed habitat. A projectthat is replacing habitat via compensatory miti-gation at a ratio of 3:1 should plan for threereplacement units/ha habitat disturbed.

A replacement unit for late-successional sagebrushsteppe will consist of:

• 20 transplanted large shrubs/ha (8/acre)

• 1000 seedlings/ha (400/acre)

• native, perennial bunchgrass understory.

This replacement unit is based on the assumptionthat the tublings will provide the bulk of the shrubdensity and canopy coverage replacement. Datacollected for initial monitoring of the Environ-mental Restoration Disposal Facility (ERDF)indicates that an average mature sagebrush is124 cm tall with a cross-sectional area of 1.6 m2.Therefore, to recreate a shrub community thatmeets the minimum definition of late-successionalsagebrush steppe (10% shrub cover), a minimumof 625 surviving shrubs/ha is required. If a tublingsurvival rate of 60% is assumed, an initial plantingof 1000 tublings/ha is needed.

Transplanted mature shrubs will provide structuraldiversity and avian perch sites, and will functionas immediate seed sources for the community.Transplanted shrubs should be at least 50 cm tall,with at least 20% greater than 100 cm tall. Alltransplanted shrubs should be of the dominantspecies in the disturbed area.


Habitat replacement at the point of impact mayrequire that the native understory be recreated. If aselected mitigation area already has suitable coverof native perennial grasses, additional understorymanipulations may not be required.

Alternatives to any of the interim requirementsmay be developed on a case-by-case basis, as longas the functional aspects of the requirements arepreserved. For example, instead of transplantingmature shrubs, a project may choose to increasethe seedling density and install artificial perches;this would increase plant density, provide futureseed sources, and provide some physical structure,thus preserving the functional contributions of themature shrubs.

Methods used for habitat improvement will varyaccording to specific site conditions and mitigationgoals. Methods to be considered include salvagingplant material and topsoil, site preparation, soilamendments, plant species selection, and plantingmethods. McLendon and Redente (1997) providean overview of many habitat improvementmethods applicable to the Hanford Site.

Mitigation actions that involve habitat amend-ment, reclamation, or creation will require plantmaterial that is both native and locally adapted. Tomeet these needs, DOE-RL supports the concept ofnative plant nurseries and/or native grass farms toprovide locally derived plant material for revegeta-tion purposes. Several approaches to the creationand operation of such facilities are possible asdescribed below:

• create a nursery and/or farm located on theHanford Site that would be constructed andoperated with DOE funding by one or more ofthe existing Site contractors

• create a nursery and/or farm located on or nearthe Hanford Site that would be constructedwith DOE funds and operated under contractby either a private vendor or by DOE incooperation with Natural Resource Trustees,Tribes, or resource agencies

• create a nursery and/or farm located on or nearthe Hanford Site that would be constructed andoperated by a private vendor.

Many native species, including shrubs, perennialforbs, and some grasses, are most effectivelyplanted as transplants. These transplants can beeither plants salvaged from local areas undergoingdisturbance or plants grown from locally collectedseed. In either case, a nursery may be requiredeither to maintain salvage plants or to propagateenough material to meet the mitigation needs ofthe Hanford Site.

A native plant nursery must be able to provide alarge number of shrubs and perennial forbs eachyear. These plants must originate from the HanfordSite, either as seed or salvaged plants. The nurseryshould be capable of providing shrubs in both theform of seedlings or 1-year-old tublings and aslarger plants in at least 5- to 10-gal pots. Perennialforbs should represent the full range of nativespecies diversity that occurs in all areas that willrequire mitigation.

Perennial bunchgrasses also should be grown inthe nursery to support improvement of smallmitigation sites, increase the grass diversity inlarger mitigation areas, and for sites where directtransplanting is desired because existing shrubscould be damaged by direct seeding methods.

Mitigation actions that require establishing peren-nial grasses on a large scale are not cost effectivelyaccomplished using transplants. Drill or broadcastseeding native grasses results in considerable costand time savings.

A native grass farm should be constructed andoperated to provide a sustainable crop of locallyadapted seed that can support all revegetationactivities on the Hanford Site. The crops should bepropagated from locally collected seed and grownin an agricultural setting that will maximize seedyield. Species that should be included in the farmare Sandberg’s bluegrass (Poa sandbergii), Indianricegrass (Oryzopsis hymenoides), needle and thread-grass (Stipa comata), sand dropseed (Sporobolus


cryptandrus), and other species if desired. Thegrasses should be planted to allow for efficientseed harvesting using standard agriculturalequipment.

Ideally, the native grass farm will be constructed inan area that is currently of low habitat quality anddominated by alien annuals. The site should benear a water source for periodic irrigation to allowfor maximum seed yield during dry years.

The DOE, through the ERC contractor, hascontracted with a private grower to produceHanford-derived grass seed. This program hasbeen successful, and similar programs should bepursued in the future.


If onsite mitigation actions do not provide fullreplacement of lost habitat value, the project maycompensate for this loss by improving habitat onlands away from the project site. In most cases, thiswill be accomplished via participation in a mitiga-tion bank. Some projects may adversely impactunique resources not covered in an establishedbank, or may have large mitigation requirementsthat cannot be met by an established mitigationbank. The following sections describe siting criteriaapplicable to siting a mitigation bank or sitingproject-specific compensatory mitigation areas.

A number of factors affect the selection of amitigation area to be used for compensation ofhabitat value lost at a project site. These factors,which involve mitigation goals, land ownership,and land-use patterns, establish a set of prioritizedcriteria that affect site selection at the landscapescale. The criteria and their hierarchy are as follow:

1. The mitigation area should be contained eitherwholly within DOE-administered or managedlands or on the Hanford Reach NationalMonument.

a. The mitigation area should be located near,within, and/or surrounding lands that possesssignificant habitat value as identified in BRMaP.

b. The mitigation area should include lands thatwill allow for in-kind replacement of habitatvalue lost at project sites.

c. The mitigation area should be placed inregions designated within the HCP-EIS asconservation or preservation.

2. If sufficient land area for in-kind mitigation isnot available on lands intended to remain underDOE control or on the Monument, then themitigation area may include nearby federal orstate owned lands that are managed for naturalresource values. This may require that protec-tion provisions, such as deed restrictions orconservation easements, be part of land transferagreements.

3. When land fitting neither of the above categoriesis available, then the mitigation area mayinclude non-DOE-managed and unprotectedlands used to achieve in-kind replacement ofresources or for protection of at-risk habitat.Thus, these resources could be presentlydegraded or could be resources of significanthabitat value threatened with development.

The first three criteria (1a, 1b, and 1c) must beconsidered together, and the alternative locationcriteria (2 and 3) should be followed in order.These criteria are designed to achieve no net lossof in-kind habitat value and a net increase in theacreage of in-kind habitat protected from futuredevelopment.

Mitigation areas should be designated on land useplans/maps or protected through deed restrictionsfor at least the duration of the impacts of the project.For this reason, mitigation areas should be locatedon lands that will remain under DOE or federaladministrative control to ensure this protection.

A crucial part of resource management is pro-tecting at-risk, high-quality habitats. Areasrecommended to be protected for their resourcevalues are identified in BRMaP. To ensure properecological functioning of the mitigation area, siteselection should account for these protected areas,and if possible, augment them.


At-risk lands do not include the Monument,because this will be protected for reasons notassociated with mitigation. If, however, habitatimprovements on Monument lands can result inan increase in the functioning and connectednessof Hanford Site resources, then habitat improve-ment on these lands is an option for compensatorymitigation.

The lowest priority means of achieving com-pensatory mitigation is the protection of adjacent,non-DOE-managed resources via acquisition or byother means. Acquisition is an option if habitatimprovement or protection of acquired lands canincrease the functioning and connectedness of theHanford resources to be mitigated. Although a lastresort, acquisition of non-DOE-managed land isfeasible when options for mitigation are reducedon DOE-managed lands.

To achieve in-kind compensation of lost habitatvalue, a proposed mitigation area must satisfyseveral technical siting criteria as described below.These criteria include factors such as proximity tothe project site, local environmental conditions,landscape features, wildlife usage, and the presenceof species of concern. The order in which thecriteria are listed does not imply any prioritization,and a selected site may satisfy some criteria to agreater extent than other criteria.

• The mitigation area should be adjacent to areasthat are already protected or to areas with com-plementary habitat if management objectivesinclude preserving a mosaic of habitat types.

• The mitigation area should be sited near thelocation of a project’s impact to increase thelikelihood that animals displaced from theproject site can use the mitigation area.

• The mitigation area should be capable ofserving as a travel corridor for wildlife, as wellas a core area of wildlife usage. Corridors mayconnect habitat areas within the Hanford Siteor connect the Hanford Site to adjacent non-DOE lands.

• The mitigation area should be able to balancethe effects of large-scale disturbance andhabitat fragmentation.

- Wildlife may not respond to habitat loss in a1:1 manner. For example, population viabil-ity may depend on the presence of a mini-mum amount of contiguous habitat. Speciesthat require a core area of unfragmentedhabitat may fail to use small parcels ofquality habitat because of edge effects andinsufficient patch sizes. Thus, wildlife usein fragmented habitats may be less thanexpected if based on the summation ofindividual habitat parcels.

- Large-scale disturbance can be natural orhuman in origin. For instance, fire is adisturbance that is highly destructive toshrub-steppe habitat. The siting of a miti-gation area should consider the local firehistory, the fire potential at and around themitigation area, and the impact of differentfire protection schemes as part of the selec-tion process. The objective is to ensure thatboth the mitigation area and the remainingnative stands of shrub-steppe will not be lostbecause of a single large fire. A mosaic ofhabitat types may help reduce the potentialfor losing all remaining stands of matureshrub-steppe habitat.

- Although fragmentation and large-scaledisturbances are competing concerns, thesiting objective is to achieve a balance thatwill minimize the severity of either impact.

• The mitigation area should be capable ofaddressing project impacts that affect species ofconcern. Thus, the selection of a mitigation areamay be partially driven by the requirements ofa particular species of concern.

• Site selection should be viewed in the contextof the surrounding landscape, including landsadjacent to Hanford. This requires informationabout the distribution of resources as well asland uses both on and adjacent to Hanford.

• Projections of foreseeable mitigation needs willenable the proper sizing of the mitigation areaor bank. Potential future expansion of themitigation area also should be addressed.

• The mitigation area should be capable ofachieving in-kind habitat value replacement viahabitat improvement. Therefore, the habitatpotential of the mitigation area and the project


impact area must be similar. If planting shrubswill be the primary mechanism for increasinghabitat value, areas with healthy native under-stories and relatively undisturbed soils shouldreceive priority consideration.

• The site should not be in a radiological controlarea or other hazardous materials managementareas.

• The mitigation area should be capable of a cost-effective increase of in-kind habitat value.Figure 10 illustrates an example using habitatmanipulation resulting in mature shrub-steppeas is the mitigation goal. Three potential miti-gation areas are compared: A) a recoveringburn area with few or no shrubs present, B) arecovering burn area with many young shrubs,and C) a cheatgrass field.

- For the same financial commitment, site A isthe most cost-effective mitigation area. Site Bwill naturally reach full ecological function-ing in a relatively short period of time;therefore, the increase in habitat value dueto manipulations will be limited. Site C ismore resistant to habitat manipulations;therefore, the increase in habitat value forthe same dollar commitment is less.

Evaluating a potential mitigation area using thecriteria listed in the previous sections will requirethe pooling and analysis of information from anumber of different sources and databases. Sitescan be considered on a landscape basis usingGeographic Information Systems (GIS) anddatabases currently in use onsite. Data layers forland ownership and use, landscape features,topography, vegetation, soils, and habitat use aregenerally available through the Hanford GIS andthe Hanford Environmental Information System(HEIS). Some information is also available throughthe ecological databases maintained by PNNL.

A GIS analysis will help screen out areas of incom-patible land use or highly disturbed areas to helpdefine potential mitigation areas. Additionalanalyses of vegetation, soils, and topographicconditions will elucidate which areas are mostsimilar in habitat potential to project impact areas.These locations then can be ranked according tothe other siting criteria. Thus, potential mitigationareas can be identified that minimize habitatfragmentation and maximize core habitat areasand wildlife travel corridors.


Gap analysis and habitat evaluation proceduresmay also be useful in selecting mitigation areas.Gap analysis examines the actual and potentialdistribution of resources and compares these withthe degree to which these resources are protected.The analysis enables protection schemes to bedevised. Habitat evaluation procedures specificto particular species and their habitats provideinformation about key habitat components.

Because the mitigation area must be protected forat least the duration of the impacts of the project(s),the selection of a mitigation area must account forcurrent land ownership, possible land transfers oreasements, risk of future development to existingunprotected habitat areas, and long-term commit-ments to land usage as a mitigation area.

The initial screening for potential mitigation areaswill start with the entire Hanford Site and assumethe current condition of each part of the landscape.At subsequent levels of analysis, specific categoriesof Hanford land will be excluded from considera-tion in the following sequence:

1. Currently developed lands (roads, buildings,waste burial sites, etc.).

2. Lands not yet developed, but identified as beingan irretrievable or irreversible commitment ofresources in an approved NEPA document orother comparable environmental analysis.

3. Lands determined to be of concern for ecologi-cal, cultural, or social reasons, in the HCP-EISand/or BRMaP.

4. Lands proposed for development, rankedaccording to the stage of the planning processthe proposal is in. Planning stages may rangefrom projects awaiting final NEPA signatures(highest ranking for land exclusion) to projectsthat have not begun the NEPA evaluationprocess (lowest ranking for land exclusion).

5. Non-specific land use guidance, such as that pro-vided in the final report of the Hanford FutureSite Uses Working Group (HFSUWG 1992).

6. Other documents or considerations about landuse.

This approach will ensure that the selection ofpotential mitigation areas considers the entireHanford Site and is ecologically based in thebroadest sense. This approach may also identifylands more suited for development than forprotection of natural resource values.

Comparing the selection of a mitigation area acrossdifferent levels of screening will indicate thetradeoffs involved between resource protectionand site development. This comparison also maysuggest alterations to proposed land uses that willenable mitigation goals to be met while allowingsite development to continue.


Mitigation actions, especially if they includehabitat improvements, must be monitored todetermine if the mitigation requirements for aproject have been satisfied. Monitoring mitigationperformance is necessary to:

• ensure that mitigation actions, including amitigation bank, meet resource maintenanceand improvement goals

• evaluate mitigation and habitat improvementmethods

• provide information to respond to contingentneeds and events

• ensure that mitigation functions in a cost-effective manner.

A monitoring program will require definition ofthe specific performance measures to be evaluated,the monitoring procedures to be followed, and thereporting procedures that will be used to distributethe monitoring results.

Performance measures for a mitigation site shouldbe based on the specific mitigation goals for thatsite. The selection of specific site performancemeasures may depend on factors such as size andlocation of the mitigation site, types of mitigationactions performed, and mitigation goals. Perform-ance monitoring should occur at least annuallyuntil the mitigation goals of a site or project havebeen met. Monitoring procedures used will dependon the specific performance measures and goalsfor a mitigation site. Performance measures mayinclude:

• native plant cover

• shrub survival and growth

• diversity of native plants

• wildlife usage

• alien plant intrusion

• structural composition of the community

• spatial pattern of vegetative components

• physical and geochemical processes such aserosion and soil microbial activity

• recruitment of planted species.

Results of the monitoring efforts should bereported annually. When applicable, this willsatisfy the annual MAP reports required by DOEorder 5440.1E. Reporting should provide informa-tion summaries to:

• track the progress of mitigation actions againstgoals

• provide means for resource agencies, naturalresource trustees, and other interested partiesto assess the relative success of the mitigationprogram

• provide the information needed by DOE-RL toidentify additional actions that may be requiredto meet mitigation goals

• provide information needed by planners todevelop efficient and cost-effective mitigationactions.


All individual project MAPs should include acontingency plan and predefined minimum per-formance levels that can be used for comparisonwith mitigation monitoring results. If the perform-ance monitoring indicates that one or more of theperformance measures are below satisfactorylevels (such as transplant shrub survival is belowpredetermined action levels, i.e. greater than 50%mortality), the mitigation bank manager, projectmanager, or the appropriate responsible officewithin DOE should consider and identify waysand means to redress the deficiencies.

In the event that all or part of a mitigation area islost due to actions or events under the control ofDOE, the mitigation bank manager, project mana-ger, or appropriate responsible office within DOEshould plan and provide for replacement or repairof the mitigation area.

In the event that all or part of a mitigation area islost due to actions or events that are beyond thecontrol of DOE, such as wildfire, the DOE will notbe responsible for replacement or repair of themitigation areas.


A number of plant species on the Hanford Site areof concern to federal and state natural resourceagencies. These species are found in almost allhabitat types on the Hanford Site, and manyeventually may be impacted by Hanford Siteactivities. Provisions should be made to ensureproject activities do not result in net losses of anyplant species of concern.

Currently, at least 47 plant species exist on theHanford Site that have been listed by federal(under 50 CFR Part 17) and state (WDNR 1997)resource agencies. Three species—Columbiabladderpod (Lesquellera tuplashensis), Umtanumbuckwheat (Eriogonum codium), and northernwormwood (Artemisia campestris ssp. borealis varwormskioldii)—are federal candidates for listing asendangered or threatened. At least four others areconsidered species of concern by the USFWS, and20 (including the three federal candidates and fourfederal species of concern) are of concern inWashington State (i.e., state endangered, threatened,or sensitive). These 20 species are defined here asplant species of concern (and considered withinBRMaP as Level 3 resources).

Impacts to plant species of concern should beavoided, and any loss of these species should bemitigated with a mitigation ratio of at least 1:1.Information about the status and distribution ofmost plant species of concern is included inSackschewsky and Downs (2001).

The remaining species include 15 that are on thestate review list. These species are of concern to theWashington Natural Heritage Program, but thereis insufficient information available to assign a

listing status of endangered, threatened, or sensi-tive. It is assumed that over time these species willeither be listed at a higher level or will be added tothe state watch list. Review list plant species areconsidered Level 2 resources within BRMaP.Avoidance and minimization of impacts to thesespecies is highly recommended, but replacementof damaged populations will normally not berequired.

There are currently 12 Hanford Site plant specieson the Washington State watch list. In general,these species were formerly listed at a higherstatus level, but were downgraded because it wasdetermined they were either more common or lessthreatened than previously believed. It should benoted, however, that several species on the watchlist (such as stalked-pod milkvetch [Astragalussclerocarpus]) were downgraded because of theirabundance and perceived protection on the HanfordSite. Many watch list species also are good indica-tors of undisturbed native habitats. Watch listspecies are considered Level 1 resources withinBRMaP. Consideration should be given to specieson the state watch list during project planning andwhile project mitigation requirements are beingdetermined.

If a plant species of concern is found at a proposedproject site, mitigation should follow the hierarchydescribed in Section 1.3. In many cases, a combina-tion of these mitigation levels may be the optimalmeans of mitigation. Each level as it applies toplant species of concern, is described in thefollowing sections.


Selecting an alternate project site is the preferredapproach for rare species conservation and is theone approach that precludes the need for addi-tional mitigation measures. Circumstances exist,however, when this option is impractical. More-over, because new populations may colonize anarea at any time, a population may not be discovereduntil after significant investments have been com-mitted to a particular site, or even after severalyears of site use and development.

If avoidance is not possible, minimization may beaccomplished by redesigning to avoid most of apopulation, thereby limiting the overall impact.This should include placement of an administra-tively controlled zone around the protected popu-lation. The control zone should be clearly delineatedto prevent inadvertent entry by pedestrians orvehicles, and site workers should be informed ofits nature and importance.

The controlled zone should be large enough to:1) support the population and provide enoughhabitat to allow for population expansion, and2) prevent adverse impacts to the population dueto its close proximity to high traffic areas, excava-tions, or areas that may receive herbicide drift.Individual plants outside the administrativecontrol zone can be transplanted within thecontrolled area. Designation of controlled zoneboundaries should be made in consultation withbiologists familiar with the species.

In some cases, it may be impractical to move aproject to an alternate location or to use adminis-trative controls to protect the population. Underthese circumstances, the next two mitigationoptions are, in order of preference, replacementof the population on the project site (rectification)and relocation of all or part of the population toan area away from the project site (compensatorymitigation). These options should be considered asa last resort, to be used only when the avoidanceand minimization options are infeasible.

If onsite replacement or offsite relocation is neces-sary, both mature plants from the site to be dis-turbed and seeds should be collected, if possible,

for the mitigation effort. The use of both life stageswill increase the probability of re-establishmentand help preserve the genetic diversity of thepopulation. The plants should be identified, marked,and provided temporary protection throughadministrative controls.

Once the plants have set seed, the seeds can becollected and the mature plants transplanted.Successful transplantation is most likely during theperiod following seed set, as this is typically aquiescent or dormant period during which waterand nutrient requirements are low. Transplantationbefore seed set may result in negligible seed produc-tion or in death of the mature plant before it canset seed.

Because many plant species of concern have specifichabitat needs (which in most cases are not com-pletely understood), it is preferable to transplant toan area that is physically and biologically similarto the site of the original population. This area maybe on the project site, in a nearby undisturbed com-munity, on another site undergoing restoration, orwithin a mitigation area or bank. The transplantsite must remain undeveloped and undisturbed.

Collected seeds should be held in a nursery wherethey can be vernalized, germinated, and nurtureduntil the seedlings are ready for outplanting. Inmost cases, seedling development should be timedto allow for late fall or early spring transplanta-tion. Seedlings should be used to replace orexpand the population impacted by projectactivities. If excess seedlings are produced, somemay be introduced to other reclamation sites or toother protected areas on the Hanford Site.

If possible, transplants should be irrigated at thetime of planting and on a regular basis thereafteruntil it can be determined that the plants cansurvive without supplemental irrigation. In mostcases, irrigation can be performed either by handor with a water truck. Long-term monitoring of thetransplanted populations is required to ensureestablishment and successful reproduction on thenew site and that mitigation requirements andgoals are met.

Methods used in transplanting mature plants,collection of seeds, treatment and germinationof seeds, and nurturing and outplanting of theseedlings should be documented to allow formethodology evaluations and for continualimprovement of the propagation methods.


It is not within the scope of this mitigation strategyto define the specific commitments applicable toany project-specific mitigation action plan (MAP).Each mitigation action plan will be unique in thetypes and amounts of resources that need to bemitigated as well as the physical and other con-straints of the project. Therefore, any project thatwill result in adverse ecological impacts will berequired to prepare a MAP that will state the par-ticular mitigation commitments that DOE willmake regarding that project. Although they mightbe issued for other reasons, project MAPs areusually prepared as part of the record of decisionfor an environmental impact statement or findingof no significant impact (FONSI) for an environ-mental assessment.

The project-specific MAP will determine, amongother issues, the appropriate:

• compensatory or rectification actions, such aswhat, how much, and where to plant

• monitoring requirements

• success criteria

• contingency actions if mitigation goals are notmet

• reporting schedule.

This mitigation strategy is intended to provide adegree of consistency to the preparation of project-specific MAPs and to provide a basis for theproject-specific determinations, recognizing thehighly variable nature of mitigation actions on theHanford Site.

Mitigation Action Plans are usually prepared todescribe how a project’s impacts will be mitigated,and usually will primarily discuss compensatory

mitigation actions. However, in some cases, aproject-specific MAP may function as a road mapdescribing how project or programmatic impactswill be avoided or minimized. An example of thistype is the MAP prepared for of the remedialaction projects in the 100 and 600 Areas Operableunits (DOE 2001c).

Mitigation Action Plans for projects that willrequire rectification or compensatory mitigationshould include sections discussing the followingareas:

• summary of project

• summary of impacts to be mitigated

• mitigation goals, objectives, and performancestandards

• description of mitigation site(s)

• description of mitigation actions

• monitoring plan

• site protection measures

• maintenance activities

• contingencies

• responsibilities

• other mitigation needs (i.e., cultural resources,dust, etc.).

Examples of project-specific MAPs that have usedthis general outline include those prepared for theSafe Interim Storage of Tank Wastes (DOE 1995b)and for Tank Waste Treatment PrivatizationInfrastructure development (DOE 1998), and theMAP for the 100 and 600 Area Remedial ActionProjects (DOE 2001c).


Brandt, C. A., W. H. Rickard, and N. A. Cadoret.1991a. Reclamation Report Basalt Waste IsolationProject Boreholes 1990. PNL-7585, Pacific NorthwestLaboratory, Richland, Washington.

Brandt, C. A., W. H. Rickard, M. G. Hefty, andN. A. Cadoret. 1991b. Interim Reclamation ReportBasalt Waste Isolation Project Near Surface TestFacility 1990. PNL-7584, Pacific Northwest Labora-tory, Richland, Washington.

Brandt, C. A., K. Alford, G. McIlveny, andA. Tijerina. 1993. Plant Re-Establishment after SoilDisturbance: Effects of Soils, Treatment, and Time.PNL-8935, Pacific Northwest Laboratory, Richland,Washington.

Calder, W. A. 1984. Size, Function, and Life History.Harvard University Press, Cambridge,Massachusetts.

Castelle, A. J., S. Luchessa, C. Conolly, M. Emers,E. D. Metz, S. Meyer, and M. Witter. 1992a. Wet-lands Mitigation Banking. Publication #92-12, Wash-ington State Department of Ecology, Olympia,Washington.

Castelle, A. J., C. Conolly, M. Emers, E. D. Metz,S. Meyer, M. Witter, S. Mauermann, M. Bentley,D. Sheldon, and D. Dole. 1992b. Wetland MitigationReplacement Ratios: Defining Equivalency. Publica-tion #92-8, Washington State Department of Ecol-ogy, Olympia, Washington.

DOE (U.S. Department of Energy). 1995a. EcologicalCompliance Assessment Management Plan. U.S.Department of Energy-RL, DOE/RL-95-11 Rev. 1,Richland, Washington.

DOE (U.S. Department of Energy). 1995b. Mitiga-tion Action Plan for Safe Interim Storage of HanfordTank Wastes Hanford Site, Richland, WA. DOE/EIS-0212MAP, Richland Operations Office, Richland,Washington.

DOE (U.S. Department of Energy). 1998. MitigationAction Plan for the U.S. Department of EnergyHanford Site, Tank Waste Remediation SystemPrivatization Phase 1 Facility Construction. RichlandOperations Office. Richland, Washington.

DOE (U.S. Department of Energy). 1999. HanfordSite Comprehensive Land-Use Plan EnvironmentalImpact Statement. DOE/EIS-0222-F, RichlandOperations Office. Richland, Washington.

DOE (U.S. Department of Energy). 2001a. HanfordSite Biological Resources Management Plan. RichlandOperations Office, DOE/L-96-32, Richland,Washington.

DOE (U.S. Department of Energy). 2001b. HanfordCultural Resources Management Plan. PNL-6942,Pacific Northwest Laboratory, Richland,Washington.

DOE (U.S. Department of Energy). 2001c. Mitiga-tion Action Plan for the 100 and 600 Areas Oper-able Units of the Hanford Site. DOE/RL-96-19,Richland Operations Office, Richland, Washington.

Durham, R.E., and M. R. Sackschewsky. 2002.W-519 Sagebrush Mitigation, FY 2002 Status Report.PNNL-14131, Pacific Northwest National Labora-tory, Richland, Washington.

Fitzner, L. E. 2000. Reproductive Ecology of the SageSparrow (Amphispiza belli) and its Relationship to theCharacteristics of Native and Cheatgrass (Bromustectorum) Dominated Habitats. M.S. Thesis, Wash-ington State University, Pullman, Washington.


Gano, K. A., A. L. Johnson, and J. K. Linville. 1999.1999 Environmental Restoration Contractor Revegeta-tion Monitoring Report. BHI-01310, Rev. 0. BechtelHanford, Inc. Richland, Washington.

HFSUWG (Hanford Future Site Uses WorkingGroup) 1992. The Future for Hanford: Uses andCleanup, The Final Report of the Hanford Future SiteUses Working Group. U.S. Department of Energy,Richland, Washington.

Johnson, A. L. 2001. 2001 Environmental RestorationContractor Revegetation Monitoring Report. BHI-01554, Bechtel Hanford, Inc. Richland, Washington.

Johnson, A. L, K. A. Gano, and J. K. Linville. 2000.2000 Environmental Restoration Contractor Revegeta-tion Monitoring Report. BHI-01406, BechtelHanford, Inc. Richland, Washington.

McLendon, T., and E. F. Redente. 1997. RevegetationManual for the Environmental Restoration Contractor.BHI-00971 Rev. 0. Bechtel Hanford, Inc. Richland,Washington.

Noss, R. F., E. T. LaRoe III, and J. M. Scott. 1995.Endangered Ecosystems of the United States: A Pre-liminary Assessment of Loss and Degradation. Biologi-cal Report 28, U.S. Department of the Interior,National Biological Service, Washington, D.C.

Sackschewsky, M. R. 1999. Safe Interim StorageProject (Project W-058) Sagebrush Mitigation FY 1999Monitoring Report. PNNL-14122, Pacific NorthwestNational Laboratory, Richland, Washington.

Sackschewsky, M. R., and J. L. Downs 2001. Vascu-lar Plants of the Hanford Site. PNNL-13688, PacificNorthwest National Laboratory, Richland, Wash-ington.

USFWS (U.S. Fish and Wildlife Service). 1980.“Habitat Evaluation Procedures (HEP),” EcologicalServices Manual 102, USFWS, Department of theInterior, Washington, D.C.

USFWS (U.S. Fish and Wildlife Service). 1981. Stan-dards for the Development of Habitat Suitability IndexModels. Ecological Services Manual 102, USFWS,Department of the Interior, Washington, D.C.

USFWS (U.S. Fish and Wildlife Service). 1988. Miti-gation Banking, Biological Report 88(41). USFWS,Department of the Interior, Washington, D.C.

WDFW (Washington Department of Fish andWildlife). 1999. Requiring or Recommending Mitiga-tion. POL-M5002. Washington Department of Fishand Wildlife, Olympia, Washington.

WDNR (Washington Department of NaturalResources). 1995. State of Washington NaturalHeritage Plan. 1993/1995 update. Olympia,Washington.

WDNR (Washington Department of NaturalResources). 1997. Endangered, Threatened, and Sensi-tive Vascular Plants of Washington. WashingtonNatural Heritage Program, Olympia, Washington.


ALE Fitzner/Eberhardt Arid Lands EcologyReserve

AMC Assistant Manager for Infrastructureand Closure

BLM Bureau of Land Management

BRMaP Biological Resources Management Plan

BRMiS Biological Resources MitigationStrategy

BWIP Basalt Waste Isolation Project

CEQ Council on Environmental Quality

CLO Closure Division, U.S. Department ofEnergy, Richland Operations Office

CFR Code of Federal Regulations

CERCLA Comprehensive EnvironmentalResponse, Compensation, and LiabilityAct

DOE U.S. Department of Energy

EA Environmental Assessment

ECAMP Ecological Compliance AssessmentManagement Plan

ECR Ecological Compliance Review

EIS Environmental Impact Statement

E.O. Executive Order

ERC Environmental Restoration Contractor

ERDF Environmental Restoration DisposalFacility

ESA Endangered Species Act

FONSI Finding of No Significant Impact

FR Federal Register

GIS Geographic Information System

HEIS Hanford Environmental InformationSystem

HEP Habitat Evaluation Procedure

HCP-EIS Hanford Site Comprehensive Land UsePlan - Environmental Impact Statement

HSI Habitat Suitability Index

HU Habitat Unit

MAP Mitigation Action Plan

MOU Memorandum of Understanding

NEPA National Environmental Policy Act

PNNL Pacific Northwest National Laboratory

RCC River Corridor Contractor

RI/FS Remedial Investigation/FeasibilityStudy

RL DOE Richland Operations Office

ROD Record of Decision

TPA Tri-Party Agreement

USFWS U.S. Fish and Wildlife Service

U.S.C United States Code

WDFW Washington Department of Fish andWildlife

WDNR Washington Department of NaturalResources

WDOE Washington Department of Ecology

WNHP Washington Natural Heritage Program


AVOIDANCE: Mitigation actions that rely onelimination of all or part of a project, or changesto project timing, location, or structural modifi-cations to completely avoid adverse impacts tobiological resources. Avoidance is the first stepin the mitigation hierarchy.

BANK CREDIT: Increased habitat value derivedfrom habitat improvements on a mitigationbanking site. Habitat improvements identifiedas mitigation banking credits are typicallyimplemented before project impacts take place.Pre-existing habitat value does not count ascredit.

BANK DEBIT: Decreased habitat value on projectsites that result from project impacts to biologi-cal resources. Bank debits are offset by bankcredits.

BIOLOGICAL RESOURCE: A biological species,population, species assemblage, habitat, com-munity, or ecosystem. If a biological resourceis of management concern, it may also be amitigable resource.

COMPENSATION: Amelioration of project impactsby replacing lost habitat value away from aproject site. Can be accomplished by eitherhabitat improvement or by acquisition andprotection of substitute, high-quality resources.Compensation is the last step in the mitigationhierarchy.

CORRECTIVE ACTION (MITIGATION): Actionstaken following the unsuccessful implementa-tion of mitigation measures that ensure project-specific mitigation objectives are met.

ECOLOGICAL COMPLIANCE REVIEW: Anassessment of the potential for a proposedproject to adversely impact biological resources.

ENHANCEMENT: An improvement in the valueof an existing habitat. Under USFWS policy,enhancement specifically refers to habitatimprovements that are independent of miti-gation commitments or waste site restorationactions.

EVALUATION SPECIES: A species selected foranalysis in habitat suitability index models.

HABITAT: The combination of biotic and abioticcomponents that provides the ecological sup-port system for plant or animal populations.

HABITAT AMENDMENT: Increasing habitatvalue by supplementing an area that alreadycontains some of the desired habitat compo-nents with missing habitat components.

HABITAT CREATION: The establishment of afunctioning habitat in essentially abiotic areaswith little or no existing habitat value. Thecreated habitat may or may not resemble theoriginal habitat of the site.

HABITAT EVALUATION PROCEDURE: Amethod used to document the quality andquantity of available habitat for selectedwildlife species.

HABITAT IMPROVEMENT: An increase inhabitat value through amendment, reclama-tion, or creation.


HABITAT SUITABILITY INDEX: A model-basedestimate, ranging from 0 to 1 of the utility ofthe habitat in a specific area to support anevaluation species. A value of 1 indicatesoptimal habitat; a value of 0 indicates the areais unusable by the evaluation species.

HABITAT UNIT: The unit of currency in habitatevaluation procedures that takes into accountboth the quality and quantity of habitat. Habi-tat Units = Quality (HSI value) x Quantity (area).

HABITAT VALUE: The suitability of an area tosupport selected animal and/or plant evalua-tion species.

HOME RANGE: The land area required for ananimal species to survive and/or successfullyreproduce.

IN-KIND MITIGATION: Replacement of losthabitat value with substitute resources thatclosely approximate that lost, so populationsof species associated with that habitat mayremain relatively stable in the area over time.

LANDSCAPE SCALE: A scale of ecological evalu-ation that includes multiple habitat types,ecosystems, and land uses.

MINIMIZATION: Mitigation actions that rely onchanges to project timing, location, or struc-tural modifications that minimize adverseimpacts to biological resources. There may stillbe some residual adverse impacts to mitigableresources following minimization. Minimizationis the second step in the mitigation hierarchy.

MITIGABLE RESOURCE: A biological resource(species or habitat) considered rare, threatened,or in need of special management and/orprotection. Adverse impacts to these resourcesmay require mitigation actions.

MITIGATION: a series of prioritized actions that,when achieved in full, ensure project impactswill result in no net loss of habitat value orwildlife populations. The sequence of mitiga-tion actions proceeds from the highest tolowest priority as follows: 1) avoid the impactaltogether, 2) minimize the impact, 3) rectifythe impact by restoring the affected environ-ment, and 4) compensate for the impact byreplacing or providing substitute resourcesor environments.

MITIGATION ACTION PLAN (MAP): DOEdocument, usually associated with a ROD foran EIS, or if mitigation is specified within aFONSI for an EA, that explains how mitigationcommitments will be planned and imple-mented [see DOE’s NEPA implementingprocedures (10 CFR 1021.104 and 10 CFR1021.331)].

MITIGATION AREA: Any area either onsite oroffsite where habitat improvements occur aspart of a mitigation commitment. An offsitemitigation area may include lands that arededicated to both a mitigation bank andcompensation areas.

MITIGATION BANKING: Habitat improvementactions taken for the specific purpose of com-pensating for unavoidable losses before theimpacts occur. Allows for a mitigation credit/debit system and for compensatory actions formultiple projects to be coordinated.

MITIGATION THRESHOLD LEVEL: The level ofhabitat value reduction that will trigger therequirements for rectification and/or com-pensatory mitigation.

MONITORING: Collection of specific types ofdata to determine if the goals and objectivesof project-specific mitigation or the mitigationbank are met.

OFFSITE: Away from the project site and, unlessotherwise specified, still within the HanfordSite boundary.

ONSITE: The location where project impacts tobiological resources occur.

OUT-OF-KIND MITIGATION: Replacement oflost habitat value with substitute resources thatare physically or biologically different fromthose lost.

PRIORITY HABITAT: A habitat designated byWDFW as having unique or significant valueto many wildlife species.

PRIORITY SPECIES: Wildlife species designatedby WDFW that require protective measures fortheir perpetuation due to their populationstatus, sensitivity to habitat alteration, and/orrecreational importance.


PRODUCTIVITY: The amount of energy orbiomass accumulated by an individual, popu-lation, or community during a specific timeperiod.

PROJECT: Any activity that has the potential toimpact biological resources such as facilitymodification, privatization, testing, remedia-tion, or construction. This is not equivalent tothe DOE 4700.1 “Project Management System”definition of “project,” which is limited toclassical construction projects.

RECLAMATION: Improvements to the value ofhabitat degraded by anthropogenic disturb-ance. Reclamation is intermediate to habitatcreation and habitat amendment.

RECTIFICATION: Amelioration of project impactsby replacing lost habitat value at the projectsite. Rectification is the third step in the miti-gation hierarchy.

REMEDIATION (WASTE SITE): Actions taken toremove or isolate physical, chemical, or radio-logical hazards at a past practice waste site.

REPLACEMENT RATIO: The ratio of the areaover which mitigation measures are applied tothe area receiving adverse impacts (assumingequivalent habitat value at each site). Alter-natively, it can be the ratio of the improvedhabitat value at the mitigation area to the habitatvalue at an impacted site (assuming the sameland area for each site).

RESTORATION (WASTE SITE): Actions taken tocreate habitat value at a past practice waste sitesubsequent to the completion of remediation.

SPECIES OF CONCERN: For fish and wildlife,any federal endangered, threatened, orcandidate species; species covered under theMigratory Bird Treaty Act; and any additionalspecies identified as Washington State priorityspecies. For plants, any federal endangered,threatened, or candidate species plus anyadditional species identified as a WashingtonState endangered, threatened, sensitive, ormonitor species.


AVOIDANCE: Mitigation actions that rely onelimination of all or part of a project, or changesto project timing, location, or structural modifi-cations to completely avoid adverse impacts tobiological resources. Avoidance is the first stepin the mitigation hierarchy.

BANK CREDIT: Increased habitat value derivedfrom habitat improvements on a mitigationbanking site. Habitat improvements identifiedas mitigation banking credits are typicallyimplemented before project impacts take place.Pre-existing habitat value does not count ascredit.

BANK DEBIT: Decreased habitat value on projectsites that result from project impacts to biologi-cal resources. Bank debits are offset by bankcredits.

BIOLOGICAL RESOURCE: A biological species,population, species assemblage, habitat, com-munity, or ecosystem. If a biological resourceis of management concern, it may also be amitigable resource.

COMPENSATION: Amelioration of project impactsby replacing lost habitat value away from aproject site. Can be accomplished by eitherhabitat improvement or by acquisition andprotection of substitute, high-quality resources.Compensation is the last step in the mitigationhierarchy.

CORRECTIVE ACTION (MITIGATION): Actionstaken following the unsuccessful implementa-tion of mitigation measures that ensure project-specific mitigation objectives are met.

ECOLOGICAL COMPLIANCE REVIEW: Anassessment of the potential for a proposedproject to adversely impact biological resources.

ENHANCEMENT: An improvement in the valueof an existing habitat. Under USFWS policy,enhancement specifically refers to habitatimprovements that are independent of miti-gation commitments or waste site restorationactions.

EVALUATION SPECIES: A species selected foranalysis in habitat suitability index models.

HABITAT: The combination of biotic and abioticcomponents that provides the ecological sup-port system for plant or animal populations.

HABITAT AMENDMENT: Increasing habitatvalue by supplementing an area that alreadycontains some of the desired habitat compo-nents with missing habitat components.

HABITAT CREATION: The establishment of afunctioning habitat in essentially abiotic areaswith little or no existing habitat value. Thecreated habitat may or may not resemble theoriginal habitat of the site.

HABITAT EVALUATION PROCEDURE: Amethod used to document the quality andquantity of available habitat for selectedwildlife species.

HABITAT IMPROVEMENT: An increase inhabitat value through amendment, reclama-tion, or creation.


HABITAT SUITABILITY INDEX: A model-basedestimate, ranging from 0 to 1 of the utility ofthe habitat in a specific area to support anevaluation species. A value of 1 indicatesoptimal habitat; a value of 0 indicates the areais unusable by the evaluation species.

HABITAT UNIT: The unit of currency in habitatevaluation procedures that takes into accountboth the quality and quantity of habitat. Habi-tat Units = Quality (HSI value) x Quantity (area).

HABITAT VALUE: The suitability of an area tosupport selected animal and/or plant evalua-tion species.

HOME RANGE: The land area required for ananimal species to survive and/or successfullyreproduce.

IN-KIND MITIGATION: Replacement of losthabitat value with substitute resources thatclosely approximate that lost, so populationsof species associated with that habitat mayremain relatively stable in the area over time.

LANDSCAPE SCALE: A scale of ecological evalu-ation that includes multiple habitat types,ecosystems, and land uses.

MINIMIZATION: Mitigation actions that rely onchanges to project timing, location, or struc-tural modifications that minimize adverseimpacts to biological resources. There may stillbe some residual adverse impacts to mitigableresources following minimization. Minimizationis the second step in the mitigation hierarchy.

MITIGABLE RESOURCE: A biological resource(species or habitat) considered rare, threatened,or in need of special management and/orprotection. Adverse impacts to these resourcesmay require mitigation actions.

MITIGATION: a series of prioritized actions that,when achieved in full, ensure project impactswill result in no net loss of habitat value orwildlife populations. The sequence of mitiga-tion actions proceeds from the highest tolowest priority as follows: 1) avoid the impactaltogether, 2) minimize the impact, 3) rectifythe impact by restoring the affected environ-ment, and 4) compensate for the impact byreplacing or providing substitute resourcesor environments.

MITIGATION ACTION PLAN (MAP): DOEdocument, usually associated with a ROD foran EIS, or if mitigation is specified within aFONSI for an EA, that explains how mitigationcommitments will be planned and imple-mented [see DOE’s NEPA implementingprocedures (10 CFR 1021.104 and 10 CFR1021.331)].

MITIGATION AREA: Any area either onsite oroffsite where habitat improvements occur aspart of a mitigation commitment. An offsitemitigation area may include lands that arededicated to both a mitigation bank andcompensation areas.

MITIGATION BANKING: Habitat improvementactions taken for the specific purpose of com-pensating for unavoidable losses before theimpacts occur. Allows for a mitigation credit/debit system and for compensatory actions formultiple projects to be coordinated.

MITIGATION THRESHOLD LEVEL: The level ofhabitat value reduction that will trigger therequirements for rectification and/or com-pensatory mitigation.

MONITORING: Collection of specific types ofdata to determine if the goals and objectivesof project-specific mitigation or the mitigationbank are met.

OFFSITE: Away from the project site and, unlessotherwise specified, still within the HanfordSite boundary.

ONSITE: The location where project impacts tobiological resources occur.

OUT-OF-KIND MITIGATION: Replacement oflost habitat value with substitute resources thatare physically or biologically different fromthose lost.

PRIORITY HABITAT: A habitat designated byWDFW as having unique or significant valueto many wildlife species.

PRIORITY SPECIES: Wildlife species designatedby WDFW that require protective measures fortheir perpetuation due to their populationstatus, sensitivity to habitat alteration, and/orrecreational importance.


PRODUCTIVITY: The amount of energy orbiomass accumulated by an individual, popu-lation, or community during a specific timeperiod.

PROJECT: Any activity that has the potential toimpact biological resources such as facilitymodification, privatization, testing, remedia-tion, or construction. This is not equivalent tothe DOE 4700.1 “Project Management System”definition of “project,” which is limited toclassical construction projects.

RECLAMATION: Improvements to the value ofhabitat degraded by anthropogenic disturb-ance. Reclamation is intermediate to habitatcreation and habitat amendment.

RECTIFICATION: Amelioration of project impactsby replacing lost habitat value at the projectsite. Rectification is the third step in the miti-gation hierarchy.

REMEDIATION (WASTE SITE): Actions taken toremove or isolate physical, chemical, or radio-logical hazards at a past practice waste site.

REPLACEMENT RATIO: The ratio of the areaover which mitigation measures are applied tothe area receiving adverse impacts (assumingequivalent habitat value at each site). Alter-natively, it can be the ratio of the improvedhabitat value at the mitigation area to the habitatvalue at an impacted site (assuming the sameland area for each site).

RESTORATION (WASTE SITE): Actions taken tocreate habitat value at a past practice waste sitesubsequent to the completion of remediation.

SPECIES OF CONCERN: For fish and wildlife,any federal endangered, threatened, orcandidate species; species covered under theMigratory Bird Treaty Act; and any additionalspecies identified as Washington State priorityspecies. For plants, any federal endangered,threatened, or candidate species plus anyadditional species identified as a WashingtonState endangered, threatened, sensitive, ormonitor species.

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