CWG Review 1: Spring 2015
Tier 1 Information:
1. Management Action
S-108 Revise/create UMAM (Uniform Mitigation Assessment Method) for coral reef environments to improve
application of this rule to coastal ecosystems, to provide more consistent/accurate calculations, and to ensure
ecological functions are maintained.
2. Intended Result (Output/Outcome)
What is the end product/result of this management action?
 This action will result in more consistent and accurate mitigation calculations by various regulatory agencies and
stakeholder groups.
3. Duration of Activity
Is this a discrete action or a recurring activity? Explain.
 This action is a discrete activity. The revision of UMAM involves a rulemaking process.
4. Justification
What issue or problem will this management action address? Explain.
 The UMAM rule that is currently used for coastal ecosystems was designed for freshwater wetlands; lack of
consistency in application of this rule and resulting differences in calculations between regulatory agencies and
other stakeholders that use this rule has been identified as a problem.
5. Potential Pros
What are the potential advantages associated with this management action?
 This action will result in more consistent and accurate mitigation calculations by various regulatory agencies and
stakeholder groups, ensuring that functions provided by coastal ecosystems are maintained. UMAM rule will be
more appropriate for coastal ecosystems.
6. Potential Cons
What are the potential disadvantages associated with this management action?
 There will be learning-curve for users adjusting to the new UMAM rule, and training will be required to bring
everyone up-to-speed. Regulatory agencies will need to invest time into development, testing, training,
implementation, and enforcement of the new rule.
7. Location
County/Counties: Miami-Dade, Broward, Palm Beach, Martin, Other?
 This management action is intended to be applied statewide, including all counties in the SERCRI region.
Relevant Habitats: Coral reef, seagrass, watershed, etc.?
 This management action would be relevant to all habitat types, but it is most applicable to hardbottom, coral
reefs, and submerged aquatic vegetation.
Specific Location: City, site name, coordinates, etc.?
  -
8. Extent
Area, number, etc.

This management action is large-scale and long-term.
9. Is this action spatial in nature?
 Yes
Do you believe this management action could be informed by the Our Florida Reefs Marine Planner Decision Support
Tool?
If yes, you will proceed to the next section on Marine Planner Information.
 No
Marine Planer Information:
N/A
Tier 2 Information:
WHY?
1. Strategic Goals & Objectives to be Achieved
Refer to the SEFCRI Coral Reef Management Goals and Objectives Reference Guide.
 Goal C4 Obj 4 – Improve consistency and level of enforcement of current rules and regulations. MICCI Issue 1
Goal Obj 1 – Review, revise, implement and enforce existing regulations. Increase effectiveness of permit
conditions to protect coral communities and increase efficiency of regulatory review. MICCI Issue 1 Goal –
Protect coral systems from impacts associated with projects in and around the reef tracts of southeast Florida.
MICCI Issue 1 Goal Obj 1 – Review, revise, implement and enforce existing regulations.
 Increase effectiveness of permit conditions to protect coral communities and increase efficiency of regulatory
review. MICCI Issue 2 Goal – Change coastal construction practices in ways that protect marine and estuarine
habitats. MICCI Issue 3 Goal Obj 3 – Evaluate and promote environmentally appropriate artificial reef
construction that does not adversely affect natural marine habitats. Other Strategic Management Goals A4 Obj 3
– Create consistent standards and best management practices for restoration and compensatory mitigation
projects.
2. Current Status
Is this activity currently underway, or are there planned actions related to this recommendation in southeast
Florida? If so, what are they, and what is their status.
 Yes, FDEP is currently revising UMAM for coastal ecosystems. A worksheet for hardbottom and coral habitats is
being developed.
3. Intended Benefits (Outcomes)
What potential environmental benefits or positive impacts might this management action have?
 This action will result in more consistent and accurate mitigation calculations by various regulatory agencies and
stakeholder groups, ensuring that functions provided by coastal ecosystems are maintained. UMAM rule will be
more appropriate for coastal ecosystems.
What potential social/economic benefits or positive impacts might this management action have?
 Revision of the UMAM rule may result in a more efficient process (after an initial learning curve); the process
may allow for a better understanding of calculations by the public which may lead to a more positive perception
of UMAM in general.
What is the likely duration of these benefits - short term or long-lasting? Explain.
 Benefits are expected to be long-term because mitigation activities have long-term consequences and projects
are on-going.
4. Indirect Costs (Outcomes)
What potential negative environmental impacts might this action have?
 None
What potential negative social/economic impacts might this action have?
 There will be learning-curve for users adjusting to the new UMAM rule, and training will be required to bring
everyone up-to-speed. Regulatory agencies will need to invest time into development, testing, training,
implementation, and enforcement of the new rule.
What is the likely duration of these negative impacts - short term or long-lasting? Explain.
 Any negative impacts are expected to be short-term.
5. Risk
What is the threat of adverse environmental, social, or economic effects arising from not implementing this
action?
 The UMAM rule that is currently used for coastal ecosystems was designed for freshwater wetlands; lack of
consistency in application of this rule and resulting differences in calculations between regulatory agencies and
other stakeholders that use this rule has been identified as a problem. Inaccuracy and inconsistency in
mitigation calculations may compromise the maintenance of ecosystem functions provided by coastal habitats.
6. Relevant Supporting Data
What existing science supports this recommendation? (Provide citations)
 62-345, F.A.C. is the Rule which governs UMAM, as well as 373.414., F.S.
7. Information Gaps
What uncertainties or information gaps still exist?
  -
WHEN?
8. Anticipated Timeframe for Implementation
How long will this recommendation take to implement?
 0 - 2 years
9. Linkage to Other Proposed Management Actions
Is this activity linked to other proposed management recommendations?
 Yes
 If so, which ones, and how are they linked? (e.g., is this activity a necessary step for other management actions to
be completed?)
 This management action is linked to recommended management actions that pertain to coastal construction
and mitigation activities.
Does this activity conflict with other existing or proposed management actions?
 No
WHO?
10. Lead Agency or Organization for Implementation
What agency or organization currently has/would have authority? Refer to the Agencies and Actions Reference
Guide.
 Florida Department of Environmental Protection has the rule-making authority to implement this action.
11. Other Agencies or Organizations
Are there any other agencies or organizations that may also support implementation? Explain.
 Yes, local regulatory agencies, including the water management districts are involved in the implementation of
this rule revision.
12. Key Stakeholders
Identify those stakeholders most greatly impacted by this management action, including those from whom you
might expect a high level of support or opposition. Explain.
 Any stakeholders involved in coastal construction activities (including permittees and regulatory agencies) will
be most greatly impacted by this management action.
HOW?
13. Feasibility
Is there appropriate political will to support this? Explain.
  What are the potential technical challenges to implementing this action? Has it been done elsewhere?
 There will be learning-curve for users adjusting to the new UMAM rule, and training will be required to bring
everyone up-to-speed. Regulatory agencies will need to invest time into development, testing, training,
implementation, and enforcement of the new rule.
14. Legislative Considerations
Does the recommendation conflict with or actively support existing local, state, or federal laws or regulations?
Explain.
 This action does not conflict with any laws or regulations.
15. Permitting Requirements
Will any permits be required to implement this action? Explain.
 No, but permit requirements can be used to implement this action. Once adopted, UMAM is required by
Statute.
16. Estimated Direct Costs
Approximately how much will this action likely cost? (Consider one-time direct costs, annual costs, and staff time,
including enforcement.)
  Will costs associated with this activity be one-time or recurring?
 Recurring, much staff time is involved, when considering staff Rule development process, and indefinitely
working with new Rule. Regulatory agencies will need to invest time and money in order to revise the UMAM
rule and to offer training.
If recurring, approximately how long will staff time and annual costs be necessary to implement the management
action?
 Indefinitely, as staff will continue to implement Rule.
17. Enforcement
Does this require enforcement effort?
 Yes
Provide an explanation if available.
 Enforcement can be involved once the new Rule is adopted, as use of UMAM is required by statute for
permitting.
18. Potential Funding Sources
Identify potential funding organizations/grant opportunities, etc.
 FDEP
19. Measurable Outcomes/Success Criteria/Milestones
How will the success of this recommendation be measured? How will you know when the intended result is
achieved?
 The consistency of UMAM scores between regulatory agencies and groups of individuals can be measured;
success will have been achieved when mitigation acreage calculations are comparable to the previous UMAM,
but the consistency of scores between users has improved.
SEFCRI/TAC Targeted Questions:
1. TAC - Is the recommendation likely to achieve the intended result? Explain.
Tier 1 – #2 (Intended Result - Output/Outcome)
 Team 4: A MA worth pursuing because the state is required to use UMAM not necessarily because the UMAM is
the approach. Appreciate the level of detail and thought included in the MA - much more than most. The driving
force of this MA should not be 'consistency of use" - it should be to get results which will define more
appropriate mitigation.
 Ultimately this MA will achieve its intended result only if more appropriate mitigation activities are being
conducted which actually begin to compensate for loss services.
2. TAC - Is the recommendation sufficient to address the identified issue or problem? Explain.
Tier 1 – #4 (Justification)
 Team 4: Much better that most!
3. TAC - Is the recommendation technically achievable from a science or management perspective? Explain.
Tier 2 – #8 (Anticipated Timeframe for Implementation) and Tier 2 - #13 (Feasibility)
 Team 4: Yes - a 'better' UMAM is achievable.
 TAC Team 4: (See original PDF for full discussion)
 Mitigation Theme: Linked 5 MAs together – S12, N132, N99, S108, N117
 These are worth pursuing, and important for SEFL especially for mitigating for lost services caused by impact.
 There is no real feedback to define success of mitigation –how can this be incorporated into the project itself.
 If DEP is required to use UMAM they should develop one for the reef. There should be some input by other local
stakeholders etc.
 LW- FDEP is developing a UMAM specific to reef resources and the group is made of project sponsors
consultants and agency individuals.
 Struggle is to define the major questions that go into mitigation: what are the services or functions of the
resource lost. Information about recover times and trajectories. These are key processes that need to be
addressed when revising UMAM
 Overall need a strategy and consensus when pursuing mitigation in SEFL.
 TAC Comments:
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PD: There needs to be a framework to determine how much can really be done (e.g., a ‘carrying
capacity’ of sorts). Mitigation isn’t necessarily putting back a particular piece, it needs to consider
ecological function that is destroyed.
MM: If the resource is being destroyed anyways, we need to be more proactive in mitigating for that
loss. It’s hard to define ecological function – that would need to be better defined if we were to pursue
this as a ‘framework.’ Develop a regional strategy for being proactive with mitigation.
It’s hard to provide 100% return of services without understanding what those services even are. This
might be a first step.
An overall management plan/framework for coral reef conservation is the goal – these are all pieces of
the puzzle.
Mitigation framework – includes money and rules/regulations that force things to happen. This can be a
vehicle for achieving broader restoration goals. There is a practical advantage to using these strategies.
There is precedent for this approach in wetlands. Adapting this to coral reefs/coastal system will require
a lot of thought and policy details. Look at the ‘Safe Harbor Program.’
Use $ for ‘payment for ecological services’ – provides increase in services instead of just trying to replace
what was lost. Ex. Paying for decreased turbidity might result in greater fish recruitment or some other
additional benefit.
KG: UMAM has 2 parts. Qualitative at the beginning is where you define the services. This is critical part
that many people rush through. This is what ultimately determines #s for mitigation.
Mitigation becomes $$ oriented. Be careful with mitigation banking fees. It diminishes avoidance and
minimization on the front end because it is focused on paying for impacts.
EP: There is an ‘Ecosystem Services’ group working on this issue. Will provide more information.
4. SEFCRI Team, PPT & Other Advisors - Has this been done (by SEFCRI, other agencies or organizations in the SEFCRI
region)? Explain.
Tier 2 – #2 (Current Status)
 DG: It was stated that this process has begun ...
 FWC: Yes, this is already occurring.
5. SEFCRI Team, PPT & Other Advisors - Is this recommendation a research or monitoring project?
(Recommendations should be turn-dirt management actions, not the step you take before a management action).
Explain.
 DG: Both?
6. SEFCRI Team, PPT & Other Advisors - If either of the following applies to this management action, provide
feedback on which information submitted by the Community Working Groups may be more appropriate, or if
entries should be merged. Explain.
a. There are different viewpoints for an individual management action (i.e. two working group members
provided separate information, as indicated by a ‘//’ marking between them).
b. Information submitted for this and other draft management actions is sufficiently similar that they might
be considered the same.
 DG: Not similar enough to merge completely but there are a number of MAs related to issues associated with
permitted projects which would impact reef resources and they may be linked: N-132, S-12, N117, and N-99.
7. SEFCRI Team, PPT & Other Advisors - Non-agency Question: Is the recommendation technically achievable from
your stakeholder perspective? If not, do you have suggestions that would allow this to become technically
achievable from your stakeholder perspective? Explain.
Tier 1 - #5 (Potential Pros), Tier 1 - #6 (Potential Cons), Tier 2 - #3 (Intended Benefits), Tier 2 - #4 (Indirect Costs)
and Tier 2 - #12 (Key Stakeholders)
 SEFCRI Team Group Discussion:
 Several MAs relevant to beach projects. These were all very vague and hard to comment on – e.g., N106
(minimize beach renourishment projects); N98 (Develop, fund and implement BMP); S120 (Improve
management of beach renourishment projects); S124 (Facilitate creation of regional BMAs).
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Tried to provide comments to direct the CWGs; direct them to existing BMAs etc. (e.g., read the BMA and if you
have comments or concerns start there).
One MA (S108) referenced developing a UMAM, which is currently happening already.
JM: Suggestions for reports or resources that CWGs can access to further develop their MAs?
LK – USACE reports. Other tools that could help?
TJS: Public workshops/meetings over the last 1.5 years – there is a significant amount of information on DEP
website.
JT: Better management would include what are more sustainable ways to renourish the beach? Sand bypass,
move sand to hotspots. One suggestion at that Coastal Ocean Task Force is to possibly try to manage beach
projects more holistically, rather than such a localized focus. Sand bypass could be an option.
LK: CWGs are coming up with the project, not us. SEFCRI might have some ideas o JM: Ask SEFCRI to provide
specific examples of potentially viable projects in their feedback to the CWGs.
JK: There was a discussion on hotspots in the upstairs breakout group yesterday. This feedback will be seen by
CWGs.
FS: There are structures to hold sand in place. It would be a good idea to explore some of these options.
DC: Request for LK to share her ideas re: renourishment projects. Have tried to get mandatory re-vegetation to
beaches in permit applications. This has been an issue as people want clear views of the beach. Or they just
want palm trees vs. sea oats, sea grapes, etc. Some counties are better than others. The price of renourishment
has gone up (truck haul vs. dredging) the alternatives of vegetation and BMPs are starting to be more attractive.
8. SEFCRI Team, PPT & Other Advisors - Agency Question: Is the recommendation technically achievable from a
management perspective? If not, do you have suggestions that would allow this to become technically achievable
from your agency's management perspective? Explain.
Tier 2 – #10 (Lead Agency or Organization for Implementation) and Tier 2 - #11 (Other Agencies or Organizations)
 FWC: FWC is likely to support this.
 FWC: The UMAM Work Group is led by DEP and is comprised of numerous state and federal agency staff.
Comments from the Reviewers:
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(Tier 1, Q#2 – Intended Result) MJ: It is notable that the current UMAM assessment was original developed for
wetlands and is not specifically tailored to coral reefs. Note the FDEP is required to use UMAM by rule (as
opposed to HEA)
o lck-FDEP is currently creating a UMAM specifically for the aquatic environment (reference FDEP
website). The website show the draft worksheets and dates and time of the public meetings that they
are conducting for the marine aquatic UMAM analysis.
o Team 4: Generally agree - We understand the state requires at this time requires the use of UMAM. A
UMAM revised to address SEFL reefs may result in more consistent use but the tricky part is revising the
UMAM and its in puts which results in appropriate mitigation. FL is required to use UMAM and the
Federal agencies generally use HEA - would a better approach be to work with federal agencies to
improve the use of HEA approaches. A consistent approach used by all agencies would be best.
 Mitigation related MAs form an important theme that deserve better development in the
SEFCRI region. The mitigation field brings both funds and regulation that can enhance actions
and benefits to restore/enhance reef function. We see the following project numbers linking in
this theme: S12, N132, N99, S108, N117, S105
(Tier 1, Q#3 – Duration) MJ: There is functional limit to how often you could update the UMAM as it would
require rulemaking for each change. Changes would need to be significant enough to warrant rulemaking.
o Team4: We do not completely agree. A more reef appropriate UMAM should be continuously updated
and revised based on best available science. It needs to be clearly stated in the beginning of this process
that revision will occur and is necessary.
(Tier 1, Q#4 – Justification) MJ: My experience has been a consensus must be met between the regulatory
reviewer and the applicant, else the calculation is not accepted.
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(Tier 1, Q#5 – Potential Pros) Team 4. Revising the UMAM to better address SEFL reefs may increase consistency
in use. Defining 'accurate' calculations is a real challenge as well as 'ensuring that functions provided by coastal
ecosystems are maintained'.....
(Tier 1, Q#6 – Potential Cons) MJ: While it should drive the process, every time there is a rule change it does
throw a wrench into permitting and regulatory process. There would be questions regarding which version of
UMAM governs. If a project is permitted under one version of UMAM does the evaluation of project impacts
occur under that same version of UMAM or would it need to be assessed under each subsequent updated
version.
o Team 4: Yes those are time commitments but if the state is required to use UMAM there is no con to
trying to develop a more reef appropriate UMAM.
(Tier 2, Q#1 – Goals & Objectives) Team 4: Good list - This MA can be related to many SECRI and state and
Federal management goals.
(Tier 2, Q#2 – Current Status) Team 4: Good to know it is underway. Hopefully appropriate time is being
scheduled and a diverse group is being assembled to provide feedback.
(Tier 2, Q#3 – Intended Benefits) Team 4: Agree generally with the comments. Revising a UMAM to ‘accurately’
calculate appropriate mitigation is a real challenge...
(Tier 2, Q#4 – Indirect Costs) Team 4: Generally agree - the time that would need to go into this process should
not be viewed as an impact.
(Tier 2, Q#5 – Risk) Team 4: Agree
Tier 2, Q#6 – Supporting Data) MJ: Depending on the extent of recommended modifications. Changes to both
rule and statute may be required. Changes in statute require legislative aciton.
o Team 4: We may not be the best source of info on Florida statutes. There is very limited data which
really supports the effectiveness of any past mitigation activity so any movement towards improving the
decision making process is a benefit.
o Gilliam & Moulding MICCI Rpts 14,15,16 Phase 1 and 2 Moulding MICCI Rpt 27.47.48,
o OTHER MICCI Reports: Wealth of project-specific monitoring and reports since 2011 that could be better
synthesized for success/improvement
(Tier 2, Q#7 – Information Gaps) Team 4: Information gaps – really too many to list. We have many unknowns in
terms of measuring impacts and loss of ecological services and recovery times. All of these greatly influence in
puts and therefore the ‘out puts’ of a UMAM or HEA
(Tier 2, Q#8 – Timeframe) Team 4: 0-2 years would be great but may be a bit ambitious...
(Tier 2, Q#9 – Linkage to Other RMAs) Team 4: Agree. This MA may be linked to several MAs (may not be
necessary steps for the other MAs to be completed) - N-99, N-132, N117, and S-12 (all related to issues
associated with permitted projects which would impact ref resources)
(Tier 2, Q#10 – Lead Agency or Organization) MJ: If a change in statute is necessary that would require legislative
action.
o FWC: DEP
(Tier 2, Q#11 – Other Agencies or Organizations) FWC: FWC
o Team 4: Agree - but before implementation other agencies and stakeholder should be involved in the
UMAM revision process.
(Tier 2, Q#12 – Key Stakeholders) Team 4: Yes but the word 'impacted' is not appropriate. The cost of
appropriate mitigation is not an impact!
(Tier 2, Q#13 – Feasibility) Team 4: Political will? Hmmm.... Agree with there will be challenges.
(Tier 2, Q#14 – Legislative Considerations) MJ: Any change in the UMAM process would require at a minimum a
change in rule (Florida Administrative Code).
o FWC: The Board of Trustees will have to approve a new UMAM rule.
(Tier 2, Q#15 – Permitting Requirements) MJ: UMAM is required by Statute and Implemented by rule,
(Tier 2, Q#16 – Direct Costs) Team 4: OK - but the 'cost' associated with revising the UMAM is minimal compared
to the 'cost' of continuing the rate of loss services which are not being appropriately compensated....
(Tier 2, Q#19 – Measurable Outcomes) Team 4: Consistency is good but is that the real measure of the success
of a revised UMAM? Why is success achieved if calculations are comparable to previous UMAM? This is only OK
if the calculations from previous UMAMs are appropriate . Simply striving for consistency is not good enough.
Questions from the Reviewers:
Questions/Information Needs Highlighted by the Reviewers
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Questions from the CWGs back to the Reviewers:
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Not Addressed by CWG
Because:
☐ This does not apply.
☐ Need help addressing it.
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