The U.S. Environmental Protection Agency (EPA) is authorized under Section 404 of the Clean Water Act (33 U.S.C. 1344) to participate in the regulation of the discharge of dredged or fill material into waters of the United States. This regulatory authority is exercised in partnership with the U.S. Army Corps of Engineers, which has responsibility for permit issuance, and in consultation with the U.S. Fish and Wildlife Service and the National Marine Fisheries Service. Through amendments to the original statute, a series of legal actions and court decisions, and the development of operating guidance among the responsible agencies, Section 404 has evolved into the primary mechanism afforded Federal authorities for the protection of wetlands.

EPA recognizes the importance of wetlands in achieving the goals of the Clean Water Act, which are to protect and maintain the chemical, physical, and biological integrity of the Nation’s waters. EPA Administrator Lee Thomas has identified wetlands protection as among the highest of Agency priorities. EPA recognizes that bottomland hardwood (BLH) wetlands have vital and unique attributes that, if lost, would severely impact the physical, chemical, and biological integrity of the Nation's waters. As part of a broad program to better protect the Nation's wetlands, EPA has therefore identified bottomland hardwood wetlands as a priority resource requiring special attention on a national basis.

Recognizing the importance of implementing an effective, nationally consistent, and scientifically defensible regulatory program, EPA, in October 1984, issued Interim Operating Guidance to its field personnel for implementing the Section 404 regulatory program in bottomland hardwood wetlands. With the goal of improving and finalizing that guidance, EPA is sponsoring a series of workshops designed to answer key questions concerning BLH wetlands, based on the best scientific and technical information currently available. The first two workshops were directed toward summarizing existing scientific and technical knowledge concerning the functions of BLH ecosystems, the characteristics that are important to each function, and the impact of various development activities on those characteristics.

The first workshop, which was held in St. Francisville, Louisiana, in December, 1984, examined a wetland zonation concept as a framework for gaining a greater understanding of BLH structure and function. The workshop set out to determine whether characterization of BLH resources as a series of relatively distinct zones, defined by concomitant variation in hydrologic regime, soils, and vegetation, might provide the basis for a useful and scientifically sound regulatory framework. For examp1e, if certain zones are of particular importance to one or more wetland functions that the Clean Water Act was intended to protect, then the zonation concept might be useful from the perspective of how various activities should be regulated.

Discussions during the first workshop, however, indicated that the zonation concept provides, at best, only an incomplete picture of the structure and function of BLH ecosystems. In many cases, BLH functions are not limited to or closely correlated with particular zones and, furthermore, many factors other than zone are important determinants of BLH functions.

With these responses in mind, the second workshop, held at Lake Lanier, Georgia, in July, 1985, was designed to elicit information on two questions. First, if zones are not an adequate framework for understanding the functions of BLH systems, what characteristics (predictors) can be used to assess the extent to which a particular site performs these functions? And second, what are the impacts of various development activities that often occur in BLH ecosystems on those characteristics and thus on the functions themselves?

At the second workshop, individual workgroups dealing with particular subject areas (e.g., hydrology, water quality, fisheries, wildlife, ecosystem processes, and cultural/recreational/economic resources) were able to identify site characteristics that are important determinants of the performance of various functions. For example, the Hydrology Workgroup identified flood storage as one of three major hydrologic functions that BLH ecosystems perform. The workgroup then identified the most important characteristic (e.g., surface area of the site, soil saturation, and others) that determine flood storage and the likely impact of several common activities (e.g., conversion to soybean production and levee construction) on these characteristics. Some of the workgroups also provided estimates of the aggregate impact of activities, acting through all of the characteristics, on certain functions. The workgroups also identified key characteristics that could be used to identify high-value wetlands for various functions.

In addition, the workgroups pointed out a number of topics needing further examination and discussion. First, all of the workgroups identified the need to develop the technical basis and information sources to address the problem of cumulative impacts in the regulatory process. Second, most of the workgroups noted the important of contextual variables in assessing the function of a particular site. For example, the location of a BLH site in relationship to other tracts of habitat is an important variable for many wildlife species. Similarly, the extent to which a site retains or transforms contaminants is depended not only on the characteristics of the site, but also on its position in a watershed relative to contaminant inputs. And finally, several of the workgroups pointed out that assessing the impact of an activity on a function is not as simple as "adding up" the impact on individual characteristics, but may depend instead on complex interactions among characteristics. Addressing these questions, as summarized in the objectives and discussions that follow, was the focus of the third workshop, the results of which are described in this report.