February 01, 2010
David Flick, Principal and Founder, announces that Terra Technologies, Inc. has submitted Public Comments to the Kansas State Regulatory Office of the Kansas City District of the US Army Corps of Engineers in response to proposed changes to the Kansas Stream Mitigation Guidance (KSMG) document.
The Kansas City District adopted the KSMG on October 30, 2008 to quantify required stream mitigation for approved projects pursuant to Corps Regulatory Program jurisdiction under Section 10 of the Rivers and Harbors Act of 1899 and Section 404 of the Clean Water Act. Since its adoption, the KSMG has undergone a one-year trial period to assess its effectiveness at quantifying stream mitigation requirements in Kansas. During this one-year period Terra Technologies has developed many stream mitigation plans using the KSMG, which has allowed the company to gauge the overall effectiveness of the stream mitigation program with respect to ease of use, scientific accuracy, objectivity, effect on individual permittees, and equivalence to other regional stream mitigation assessment methodologies.
Terra Technologies’ comments focused on identifying both the positive aspects of the KSMG document and its weaknesses. Most of the proposed changes improve the document but some of the underlying problems in the KSMG remain unaddressed. Terra Technologies appreciates the opportunity to have commented on the proposed changes to a helpful tool for quantifying a project’s stream impacts as well as the beneficial effects of stream mitigation efforts and looks forward to continuing to work with the Corps of Engineers to improve compensatory mitigation throughout the region.
