The Challenge

Prior to 2017, Alaska lacked an In-Lieu Fee (ILF) compensatory mitigation program that specifically focused on aquatic resource restoration. Developers needing to offset impacts under Section 404 of the Clean Water Act had limited options for high-quality, local restoration projects in Southeast Alaska. There was a critical need for a legally robust program that could bridge the gap between regulatory requirements and meaningful aquatic mitigation.

Establishing the Southeast Alaska Mitigation Fund (SAMF) represented a major milestone in Alaskan environmental policy. As the lead researcher and author of the SAMF In-Lieu Fee Program Instrument, I navigated a complex six-year regulatory process, under the Clean Water Act Section 404 program, to create the first ILF program in the state to offer compensatory mitigation through aquatic resource restoration.

Phase 1: Regulatory Strategy & Inter-Agency Alignment

I initiated and facilitated a complex, six-year regulatory approval process to establish the first ILF mitigation program in Alaska offered by a non-governmental organization.

• Consensus Building: I facilitated meetings for the Inter-Agency Review Team (IRT), which included the Army Corps of Engineers, EPA, USFWS, USFS, NOAA, and DEC.

• Goal Alignment: My role was to align these diverse state and federal agencies around a shared vision for a restoration-based mitigation framework.

Phase 2: Crafting the Legal Instrument

I served as the lead researcher and author of the SAMF In-Lieu Fee Program Instrument, the foundational legal document that governs the program’s operations.

• Technical Rigor: The instrument had to meet the stringent requirements of the 2008 Clean Water Act Final Rule on Compensatory Mitigation.

• The Innovation off Credit-Debit Methodologies: the program required the development of function-based methodologies to measure ecological “lift” at restoration sites versus ecological “loss” at impact sites. I led a team of scientists and agencies to develop the field-based tools necessary to improve and measure aquatic resource mitigation outcomes.

• Wetland Credit-Debit Method (WCDM): Based on the WESPAK-SE protocol, this method calculates gains across seven group functions, including Hydrologic, Fish, and Aquatic Habitat.

• Stream Credit-Debit Method (SCDM): This utilizes a hierarchical framework of stream functions (Hydraulic, Geomorphology, Biology) to normalize treatment costs and outcomes across diverse stream types.

Phase 3: Implementation & Capacity Building

Once the program was legally established, I pivoted to ensuring its long-term viability through education and strategic partnerships.

• Regional Training: I facilitated symposiums and trainings throughout Southeast Alaska to inform consultants, Tribes, and local governments on how to utilize the program.
• Program Management: I oversaw the funding, technical and strategic development of the fund, ensuring it remained a reliable resource for aquatic resource restoration.