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I I I I I I I I I I I I I I I I I I I ES ENGINEERING'SCIENCE There is a commonly employed technique available to avoid the cost and time required to prepare a separate EA If it is initially anticipated that a potential project will likely cause significant adverse environmental impacts or be highly controversial, then the project sponsor(s) may avoid the EA process and proceed directly with the EIS process. Many subjective and project-specific factors typically influence the decision to pursue this strategy. One of the most significant factors is receiving advice from the lead federal agency (the Corps in this case) to identify procedural needs that must be satisfied to accommodate their NEP A compliance requirements. If project circumstances suggest an eventual requirement for an EIS to help make a regulatory decision, then the Corps generally suggests proceeding directly to the EIS process. A reasonable planning guideline for preparing a final EIS is 18 to 24 months. Mitigation The costs of complying with wetland mitigation requirements or commitments generally involve separate planning and implementation steps. Planning steps involve identifying conceptual mitigation approaches that are reasonably likely to receive favorable federal and state regulatory agency acceptance. Depending on the nature and complexity of the mitigation issues and proposed mitigation concepts, and on characteristics of the mitigation site(s), separate preliminary and detailed engineering drawings may be required before construction can begin. The more diverse the range of proposed mitigation measures becomes (e.g., new wetland development, existing wetland enhancement, and restoration of previous wetlands) and the more questionable the chances for achieving successful mitigation are . perceived by agency reviews, the greater the planning costs become. Costs typically increase because of the additional efforts needed to technically demonstrate to the satisfaction of agency reviewers that the concept(s) can be successful. The range of wetland mitigation planning and engineering costs varies dramatically, depending on what measures are proposed and on how expeditiously agreements can be achieved with the regulatory agencies that must approve a proposed plan. For example, a proposal to purchase and divert water to restore a previous wetland dewatered by water diversion would probably be much less expensive to plan and get approval for than a proposal to develop a wetland on a rocky side slope that requires long-term, routine maintenance. In the former case, the probability of achieving successful mitigation would be perceived as high by regulatory agencies and the planning efforts needed to implement the measures would be considered relatively low. ES is not aware of generally accepted guidelines for estimating the cost of conducting wetland mitigation planning and permitting activities. Based on our experience with projects varying in complexity, acreage, and mitigation concepts (i.e., enhancement compared to new site development), planning costs typically can range from $3,000 to $10,000 per acre of wetland requiring mitigation. Economies of scale, limited mitigation requirements, and the ability to mitigate all affected acreages using one approach and one site certainly drive potential costs to the lower end of the range. -18- 816-3-3