Continuous Improvement/Claims

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This is a list of complaints of waste (where resources are being spent without creating value). They may or may not be accurate or precise. Each complaint came from a member of a local ecosystem recovery team, either through a personal communication or an on-line form. Complaints have been rewritten in neutral and consistent language by the complaint team, while trying to retain or add nuance or detail. No complaint has been discarded unless the complaint can be confirmed as inaccurate. Some complaints are nested within other complaints.

Complaints are useful to us because they show us where we might be able to improve the efficiency or effectiveness of our work. By shining daylight on complaints from the field we get insight into our state and federal support systems. We have sorted complaints into three systems:

  1. Plan and Fund System - by which we allocate resources to pay people to do protection and restoration. Most of this is through appropriation and capital programs.
  2. Regulate and Mitigate System - where we exercise state and federal authority to constrain the actions of citizens. These authorities create mitigation markets.
  3. Coordinate System - for all the various mechanisms by which we attempt to align action among various otherwise independent actors.
Complaint|Description
Remote and web-cast meetings need to be standard and efficient to reduce wasted effort in coordination.
State and federal agencies lack the ability to analyze, remember and act on complaints about interagency function that come from the ecosystem management field.
State-federal programs have an efficient mechanism for providing information about program activities to local teams, reducing beneficial impacts.
Commerce implementation of Growth Management Act is central to ecosystem recovery, and absent from the Ecosystem Coordination Board deliberations.
The processes that lead primarily to the distribution NEP funds as implemented under the Action Agenda framework has resulted in a large redundancy of effort.
Each grant and planning system assigns unique reporting and data management tasks diverting limited local capacity from ecosystem management, and undermining collective reporting.
Project managers waste resources managing a unique budget for each grant to meet application requirements.
Each funding program uses different language to describe projects, requiring each applicant to redefine the project for that programs application.
Administration of grant match consumes critical resources limiting the rate of ecosystem recovery with unclear benefits.
There is no centralized location for funders to view and anticipate funding opportunities among federal, state and private programs.
The use of different preformance measures among programs undermines regional performance reporting.
Different programs offer different acquisition, lease, and incentive tools and have different priorities, preventing field teams from operating with a full toolkit in any one geography.
Grant program individually set the timing of RFPs and contract periods in a way that creates a range of unintended consquences.
Once acquired, conservation lands have weak mechanisms for long-term stewardship, unsupported by state-federal resources.
Floodplain management occurs under multiple authorities, operating in the same environment, with potentially conflicting goals and methods.
CREP re-enrollment at the end of the lease is constrained, which creates a risk of losing protections.
The Habitat Work Schedule is a redundant and expensive tool, the use of which is driven by complex issues, with a potentially low return on investment.
Local governments using pre-approved road contracting rosters for restoraiton work may in more expensive project costs.
Regulatory review of culvert modification is unpredictable and expensive, which shouldn't be the case a project type where there is agreement over urgency.
Different definition and mapping of critical areas across all jurisdictions creates uncertainty and cost for project development and regulatory implementation.
Innovation in shoreline armoring is disincetivized through increased costs and uncertainty during regulatory review.
The large investment necessary to create an in-lieu fee or banking system undermines the creation of real costs for ecosystem degradation.
We have no mechanism for efficiently sharing lessons from pilot effots in ecosystem markets to improve the next effort.
Reforestation reduces landowner control of their riparian zone, creating an unintended disincentive to participate in recovery.
USACE lacks the capacity to respond early in the design process to modify federal flood infrastructure, increasing risk in pursuing expensive feasibility work without understanding federal constraints.
Agricultural drainage system regulation dramatically increases costs of operation, and when combined with lack of enforcement discourages participation in recovery.
Regulatory agencies are not organized or equipped to attract landoweners to become partners in recovery, resulting in lost opportunity and capacity.
Regulation would benefit from a watershed-based authority with broad representation that can rapidly and efficiently approve small and mid-scale projects, to enable recovery.
USACE has declined to claim jurisdiction over shoreline construction above MHHW, allowing shoreline modificaiton to avoid federal review.
Currently it takes too long to obtain US Army Corps of Engineer Regulatory Permits or amendments to existing permits.
Floodplain wetland change during restoration, even if beneficial, increases regulatory complexity, resulting in unpredictable delays or costs.
Wide buffer requirements reduce the number of landowners becoming involved in stewardship of agricultural wetlands.
Local jurisdictions have difficulty increasing density in order to meet the intent of the growth management act.
Regulation does not prevent ongoing ecosystem degradation.
Applying construction turbidity control requirements to in-stream restoration is unrealistic and drives up restoration project cost.
Fish Enhancement exemption use has reduced over time increasing project costs and time.
Each restoration project in a floodplain may require a re-mapping study under FEMA requirements, greatly increasing cost or delaying restoration.
The simplification of water quality permit data undermines its potential use to adjust program actvities as this data is aggregated.
Fewer of our current restoration actions are being reviewed under the USACE Nationwide Permit #27.