Chapter 4
Options for Protecting Wetlands in Door County
The previous chapters have provided an overview of the federal, state and local laws designed to protect wetlands and the opinions that members of key stakeholder groups in Door County have about wetland protection. This chapter presents an array of strategies for protecting wetlands. These candidate strategies have emerged from the qualitative studies done for this project (thus, are the ideas and suggestions of stakeholders). They have also come from interviews with Corps, DNR, FWS, EPA, and NRCS staff outside of Door County as well as conversations with people in other regional planning commissions, counties and cities in Wisconsin, environmental groups, and staff in state and local agencies in other states. (See Appendix E for a list of contacts.) Finally, an extensive search of the Internet helped to identify and clarify candidate strategies. The chapter begins with possible strategies that could be employed by governments acting in their regulatory capacities. The chapter ends with strategies that are non-regulatory in nature, strategies that depend upon the participation of stakeholders and government.
(Back to TOC)H. L. Menken is credited with saying "for every public problem, there is a solution that is simple, easy and wrong." The nature of public issues is that they are complex and multi-dimensional, often meaning that many strategies are needed to address them. This chapter presents possible strategies to protect Door County wetlands. Each strategy presented has merit, but is insufficient by itself to protect wetland resources. Every strategy also has its own mix of political, administrative, technical and fiscal constraints. The discussion sections outline how the strategy is aligned with stakeholder concerns. The particular mix of strategies to employ will be up to citizens in the county.
(Back to TOC)Develop a Special Area Management Plan
A Special Area Management Plan, or SAMP, is a comprehensive planning process that ultimately leads to better protection of wetlands and all environmental resources. The 1980 Amendments to the Coastal Zone Management Act established the SAMP mechanism and the Corps adopted it for wetlands planning in 1988. A SAMP is approved by the Corps’ District Engineer and authorizes the recipient government to fill wetlands designated for development while protecting all other wetlands. In other words, a SAMP extends authority for the general permitting activities of the Corps to the local government. While the Corps and the EPA still maintain oversight roles, the recipient government receives permission to assume permitting duties under Section 404 for the smaller projects. SAMPs vary. Sometimes, the Corps gives one individual permit to the local government; in other cases, the Corps grants one or more general permits.
Applying for a SAMP takes several years. It requires that the applicant first inventory all wetlands and make decisions about their functional value. The ranking system does not have to be complex, but should take into account the wetland’s contribution to water quality, flood control, groundwater discharge and recharge, and fish and wildlife habitat. Several functional assessment models are available and the DNR could provide guidance on conducting a functional assessment.
After determining relative values of wetland areas, the applicant government categorizes each wetland area. For example, the community could place wetlands into three categories: those that can be developed because they have little ecological value; those that have moderate ecological value and need protection whenever possible; and, those wetlands that absolutely must be preserved because of their high functional value.
The SAMP process also requires the involvement of staff from the Corps field office, the DNR, the EPA, the Coastal Zone Management Program, FWS, local and regional planning offices, as well as citizens and local officials. A local steering committee is usually needed to oversee the process, and a technical advisory committee may be formed to help with the assessment process. After an initial scoping meeting, the Corps provides further guidance on SAMP procedures. The process varies, but generally contains these steps:
Public review and comment is sought during many of the steps of the process. Once approved, SAMPs are reviewed every ten years.
| Goals for a SAMP may include establishing predictability for landowners and developers by identifying upland and wetland areas suitable for development; a reduction in permit processing time; protection of moderate and high value wetlands and other natural resources; and a plan for compensating wetland losses. |
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Over 50 SAMPs are in place in counties, cities and watershed areas throughout the country, including one in Wisconsin.
Example: The City of Superior SAMP
The City of Superior, Wisconsin, has wetland over 25 percent of its 45 square mile corporate boundary, representing 65 percent of the land available for development (Wopat, 1998). Given this demand on wetland resources, in 1990 the EPA and the Corps suggested the that city sponsor the preparation of a SAMP. A steering and a technical committee were formed, with the technical committee comprised of staff from federal, state and local agencies.
The Superior SAMP committees determined wetland areas by the use of the Wisconsin Wetland Inventory Maps, although these maps were supplemented by aerial photography and on-site surveys of larger wetland areas. The presence of the DNR staff was especially helpful in determining the functional values of the natural resources in the area, according to Corps staff. Planners considered a range of alternative development scenarios, from "maximum development" (allowing 1,200 wetland acres to be developed) to "maximum preservation" (allowing no wetlands to be developed). After considering various development scenarios, the SAMP committees recommended filling 198 acres for development (Corps, 1996). This amount was further reduced to 143 acres when the city voluntarily withdrew several sites with high natural resource values (Wopat, 1998).
The SAMP process eventually protected more than just wetland areas: the city had 17 wetland sites, but included 19 non-wetland sites in the SAMP in order to better protect them. The 19 sites remained after the city argued that small wetlands may yet be found on the site and that the areas had high ecological value. Additionally, the process helped the city to identify all upland areas that were available for development and to identify endangered species. Finally, mitigation sites were identified and prioritized.
Conflicts arose after the Corps proposed issuing the City of Superior an individual permit, effectively giving the city complete control over issuing permits within the city boundaries (Wopat, 1998). The National Wildlife Federation objected to attenuating the permit process and to giving the city an individual permit. The environmental group also argued that a full Environmental Impact Statement (rather than an Environmental Assessment) should be prepared, that the Wisconsin Wetland Inventory Maps provided insufficient data, and that the Corps had unlawfully delegated its authority to the city. The National Wildlife Federation had similarly challenged other SAMPs located throughout the country (Wopat, 1998).
The Corps, the city, the EPA, the DNR and the National Wildlife Federation were able to reach consensus. The individual permit was replaced by five general permits, and the Corps and the DNR agreed to an abbreviated review of each proposed activity. (The permit process now gives the Corps a 20 day window to notify the applicant that the permit is incomplete, or the project becomes authorized by default.) The parties eventually agreed that the Environmental Assessment was adequate, and that the supplemental information to the Wetland Inventory Maps was sufficient.
One Corps official noted, "There were a number of products from the Superior SAMP process, one of which was an abbreviated permit process in the form of general permits. A regulatory end product that substantially reduces permit processing is the principal incentive for the Corps to participate in SAMPs. SAMPs require substantial up-front staff time and travel for the Corps, but the end result can be a regulatory product that greatly reduces future processing time and effort. For example, general permits usually only require a 20-day turnaround. In comparison, the Wal-Mart proposal in Superior, prior to the SAMP, required a 9-month permit review. The City benefitted in that they have a much improved comprehensive land use plan as a result of the SAMP process."
In 1996, the SAMP became official. The DNR provided 401 water quality certification for the SAMP and the Corps issued the five general permits. A Corps official explained, "It's...a parallel process where the City does its building permit review and the Corps separately does its Section 404 general permit review. When the City receives a building permit application they screen it to see if it involves a SAMP site. If so, it starts the SAMP process. The Corps, not the City, makes the final determination regarding Section 404 approval via a general permit." The SAMP will be reviewed in 10 years.
The city subsequently passed a SAMP zoning ordinance, establishing a SAMP overlay district, as well as permitting procedures, and the compensatory mitigation plan. The city council unanimously approved the SAMP ordinance.
Example: The Northampton County SAMP
Northampton County, Virginia, has incorporated the SAMP process into its efforts to create a sustainable county. The Nature Conservancy, local churches, businesses and local governments began a discussion of sustainable communities in the early 1990s. In 1992, Northampton County, Virginia received a grant from the Virginia Coastal Resources Management Program and the National Oceanic and Atmospheric Administration to create a SAMP. In 1993, the Northampton County Board of Supervisors appointed a Sustainable Development Task Force to spearhead a Sustainable Development Initiative throughout the county. The result was the Sustainable Development Action Strategy two years later. That strategy had three goals: the development of sustainable industries; the protection and enhancement of critical environmental resources; and, the active involvement of the entire county community in the sustainable development effort.
As a result of these tandem processes, wetlands are being protected and residents are gaining an appreciation for the cultural and natural resources in the county. Among other efforts, Northampton County has developed a Heritage Trail that links natural and cultural resources via a series of trails, wetland walks and historic sites. The county won a national planning award from the National Association of Counties for this effort.
Example: The Mill Creek SAMP
The Mill Creek SAMP in King County, Washington, has presented a challenge in bringing together officials from federal, state and local agencies, as well as development and environmental interests. The issue is the development of the last large wetland system in southern King County. The basin wetlands are also one of the last large blocks of land suitable for industrial development in the county (Scuderi, 1996).
The SAMP was initiated to address the conflict between resource protection and the need for land for development. The existing system of permits for wetland filling were unpredictable and done on a case-by-case basis. No determinations were made regarding the ecological affects of piecemeal destruction of the wetlands. In 1990, the Corps, the EPA, King County, the City of Auburn, and the city of Kent entered into an agreement to develop a SAMP. The goals of the SAMP included: to provide a balance between wetland protection and economic development; to ensure that wetland functions and values continue to be equal to or greater than those currently existing in the Mill Creek Basin; to contribute to consistency among federal, state, and local efforts for wetland protection; and provide an abbreviated Corps and local government permit process for projects meeting certain conditions and located in appropriate areas of the basin.
The first step was to inventory and characterize the wetlands of the basin (about 22 square miles). The wetland inventory identified 128 wetland systems covering over 2,500 acres (Scuderi, 1996). Following the inventory, a wetlands function and values assessment was conducted using the Wetland Evaluation Technique and the Washington State Department of Ecology rating system. Functions of wetlands were quantified using the Indicator Value Assessment methodology, a method that provides a relative estimate of the performance of wetland functions based on specific indicators.
Once completed, the next step was to develop alternatives that balanced wetland protection with economic development while maintaining no net loss of wetland functions and values. Ten alternatives were developed, allowing a maximum of 300 acres of wetlands to be developed and identifying appropriate mitigation areas for replacing lost wetland values.
Participants of the Mill Creek SAMP offer these lessons from their experience:
Discussion: Is this strategy right for Door County?
Advantages
If done correctly, a SAMP addresses many of the concerns stakeholders identified in interviews, surveys, focus groups and case studies. Specifically, a SAMP:
The appeal of a SAMP from the perspective of
identifying valuable wetlands and other ecological resources and then protecting them is
strong. A SAMP gets people together to agree on the areas that are critically important,
to assess the functional values of wetlands and to develop a plan of protecting wetlands
of moderate and high ecological value. Ultimately, a SAMP could be the most effective
regulatory tool for protecting wetlands, for it would allow the county to identify
wetlands of any size for protection. As noted a COE official from the Baltimore District
where several SAMPs are in place, "With a SAMP one may produce a map whereby the
regulators decide which permits are more important than others for the COE to conduct an
individual permit process, and which impacts need mitigation. With these decisions made in
advance of a lot of permit activity in the area, there would be a better process for
protecting important wetlands and streams, than the permit by
permit mode that most folks are wrapped up in now."
Disadvantages
As appealing as a SAMP is from the perspective of comprehensive planning, it is not without its drawbacks. Specifically, the disadvantages of the process include:
According to two DNR officials interviewed for this study, because of the time and resource commitments required, a SAMP should only be undertaken in communities that have high development pressures as well as sensitive environmental areas to protect. Door County appears to be in this category. A third DNR official noted the political issues in the county regarding countywide zoning as an obstacle to the acceptability of a SAMP. He commented, "The key is to get the support of all political entities--from your town boards to county board to legislators. Contact the state senator and capture his support. Get support from environmental groups at the outset to help prevent problems down the road. It won't be difficult getting the Corps to buy in on this [if there’s a consensus to move forward]."
Clearly, a SAMP requires the time and attention as well as the support of multiple agencies and of the public. It also requires financial resources to complete the inventory and the functional value assessment. One District Corps official in St. Paul was somewhat skeptical about the process– reinforcing the problem of fiscal and resource constraints.
Several factors are in place that reduce these disadvantages for Door County. First, key officials in the DNR have indicated that they would support a SAMP process for Door County. One official commented that "A SAMP is the only way to go if the county is really interested in protecting wetlands and its other environmental areas." Similarly, an EPA official offered support for the SAMP in Door County, and suggested that the county should apply for a wetland grant to partially fund the resource inventory. Also, Corps staff in the Green Bay field office have expressed support of a one-stop shopping system that gives the county more responsibility. They may be willing to sponsor the SAMP.
Moreover, the SAMP process fits nicely with work already underway by Door County to protect critical environmental areas and is in harmony with the Development Plan for the county. Door County Planning, with the support of the Coastal Zone Managment Program and in cooperation with a private delineator, will delineate certain wetlands this year. Recent efforts to inventory land and water resources by the Soil and Water Conservation Department could dovetail into the SAMP process. In short, Door County has projects already underway that potentially reduce the workload in creating a SAMP and that reinforce the basic concept of a SAMP.
Both the EPA and the Coastal Zone Management Program offer funding support for the development of SAMPs. Should Door County wish to pursue this strategy, it may be able to get funding to absorb all or part of the cost.
Finally, lessons learned from the City of Superior, as well as from other SAMPs, could potentially help to streamline the process for Door County. These models could provide a basis for constructive planning for a SAMP.
Should the county not want the regulatory authority provided by a SAMP, but still want to engage in a comprehensive effort to identify important environmental areas, it could pursue an Advance Identification of Disposal (ADID) study. Like a SAMP, an ADID includes mapping and identification of wetlands. A functional analysis is performed and wetlands are categorized. However, the ADID is mainly an information-gathering device and does not result in streamlining the Corps regulatory process.
In sum, this strategy offers big rewards but requires an extensive commitment by the county. Before opting for this strategy, a meeting should be held with key Corps, DNR, county, local staff and officials to determine the collective willingness to pursue a SAMP. County planning staff should also contact people where SAMPS are in place to help them make a decision regarding the appropriateness of a SAMP for Door County.
Apply for a Regional or Programmatic General Permit
Another strategy that leads to the assumption by Door County of part of the Section 404 permitting program is to apply for a regional or programmatic general permit authority (GP). In 1996, the Corps proposed a Regulatory Guidance Letter that would establish national policy on the conditions under which states, tribes and local governments could receive delegated authority for issuing permits under Section 404 of the Clean Water Act. The intention of the Corps in issuing the general permit is to "improve the regulatory process for applicants, enhance environmental protection, reduce unnecessary duplicative procedures and evaluations, and make more efficient use of limited resources." (Federal Register, April 26, 1996, p.18575). Corps field offices have the authority to issue regional general and programmatic permits, and they have issued approximately 450 of these as of 1996.
The PGP establishes the terms under which specific projects regulated by the state or local authority may be authorized by the Corps. PGPs are designed to simplify the evaluation process for both the regulatory agencies and the applicant, provide at least equivalent environmental protection of the aquatic resources, reduce unnecessary duplicative project evaluation, and promote more effective and efficient use of Corps resources. The Corp staff interviewed for this study believe that PGPs afford even greater environmental protection because combined resources of federal, state and local agencies are available and state (or local) authorities are more likely to ensure that conditions of the PGP are enforced.
As explained in Chapter 2, general permits are granted by the Corps for categories of projects that are substantially similar in nature, and result in no more than a minimal adverse effect on the environment. Approximately 50 of the Corps’ existing general permits are PGPs that were developed in conjunction with local or state authorities (Federal Register, 1996). For example, the Corps developed PGPs with several counties in Florida for waterfront residential development, and with Massachusetts, Connecticut and New Hampshire for projects regulated under each State’s wetland regulatory program. North Carolina received a programmatic general permit for projects regulated under the state’s Coastal Zone Management Program.
Door County could apply for a regional general permit authority subsequent to the acceptance of the general permit authority that may be granted to the DNR. (A general permit and letter of permission between the Corps and Wisconsin is out for public comment, and may become final in 1999, as noted in Chapter 3.) The county could also apply for a programmatic general permit authority. Finally, the county could apply for a regional general permit authority for small wetland permits.
| Provisions for PGPs include that they must be renewed every five years, and the Corps retains authority to modify, suspend or revoke the PGP. The Corps also retains its authority to require an individual Corps permit for any particular project and the Corps retains its full range of enforcement authority should the permit requirements not be met. |
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Procedures for obtaining a PGP are similar to the SAMP. An early scoping meeting with the local governments, federal and state natural resource agencies, state Coastal Zone Management Agency and others is held to discuss the PGP and identify potential concerns. Public notice (30 days minimum) describing the PGP must be given, as well as public meetings held as appropriate. As with the SAMP, the Corps will prepare appropriate environmental assessments under the National Environmental Policy Act.
The criteria established by the Corps for accepting a PGP are as follows:
The government receiving the PGP should develop a multi-category approach to review and screen projects, in effect "regionalizing" some nationwide general permits. Categories under the proposed Wisconsin GP/LOP were discussed in Chapter 2. Like the Wisconsin proposed GP/LOP, most programmatic general permits create categories by the size of the project. Massachusetts, for example, has four categories of wetland projects. Category 1 projects do not require notification of the Corps because they involve less than 5,000 square feet of fill within inland waterways or wetlands. Category 4 projects with impacts greater than 1 acre of wetlands require an individual permit from the Corps. The other categories require notification to the Corp, but do not involve a Corps review. In short, the state handles all small wetland disturbances (those under 1 acre) otherwise subject to Corps regulations.
Discussion: Is this strategy right for Door County?
Advantages
A PGP offers some of the advantages of the SAMP, but does not necessarily mean that critical wetlands or environmental resources facing piecemeal disturbance will be protected.
Following are some of the advantages of a PGP:
Disadvantages
Using a PGP as a strategy for creating a more effective and efficient wetlands protection program in Door County is not without its disadvantages. Most notably, a PGP:
In sum, applying for a programmatic or regional general permit delegation of authority from the Corps helps to address the need to reduce the confusion that people have about the multiple layers of regulation for most wetland altering activities in the county. A county PGP may also be more protective of wetlands since the county would oversee the process. It also addresses concerns about different delineations between the Corps and the DNR at small sites. Because a PGP would not identify wetlands that could be developed as would occur in a SAMP, it would not run afoul of the current wetland zoning districts. Moreover, because it does not require a comprehensive cataloging of wetlands and an assessment of their functional values, applying for a PGP is an easier and less time-consuming process than applying for a SAMP.
At the same time, a PGP lacks the protective power of a SAMP. Because a SAMP prioritizes environmental resources, it has the ability to be more protective of critical environmental areas. A SAMP also protects non-wetland resources as part of the planning process and would identify wetland boundaries, thus addressing some of the issues with the Wetland Inventory Maps. A PGP focuses on wetlands subject to Section 404 permitting.
One DNR official commented that both a PGP and a SAMP had merit as possible strategies for Door County. He suggested that the county apply for a PGP while it is undertaking the SAMP process. His reasoning was that the county would address some of its concerns relatively quickly with a PGP, but the SAMP could take 4-6 years to complete. Since a PGP is renewable every 5 years, it may make sense to transition into a SAMP at that time. Another DNR official, however, commented that it would be too confusing to do both, and that the county should pursue one or the other strategy.
Increase county authority under shoreland-wetland provisions
As noted in Chapter 2, all counties, cities and villages are required to protect wetlands in the shoreland according to standards in NR 115 (for counties) and NR 117 (for cities and villages). Shoreland-wetland districts created by the Wisconsin Wetland Inventory Maps are overlaid onto existing zoning classifications. Permitted uses in shoreland-wetlands zones are limited to hiking, fishing, hunting, swimming, boating, silviculture, pasturing of livestock and cultivation of agricultural crops, construction of gas, electric or other utility lines, and a few other uses. All other uses, such as the building of structures, are prohibited under NR 115.
Counties cannot by rule regulate wetland uses more stringently than does NR 115. For example, counties could not prohibit the cultivation of agricultural crops under NR 115 since such cultivation is a permitted activity under NR 115. Most counties opted to adopt the model ordinance proposed by DNR. However, some Wisconsin counties have varied other standards in order to be more protective of wetlands. (See the Shoreland Zoning Resource Guide: An Annotated Model Ordinance for a more extensive discussion of county shoreland ordinances.)
Thirteen county planners, several DNR officials, and a DNR attorney were contacted for information about variations from the model ordinance. Some of these variations include:
Discussion: Is this strategy right for Door County?
Advantages
Extending authority through the shoreland-wetland zoning ordinance offers these advantages:
Regulating small wetlands within the shoreland are important, but most counties miss the opportunity to regulate them because the counties rely on the Wisconsin Wetland Inventory Maps. Approaches that provide greater protection for small wetlands include the ability to make field determinations regarding wetlands or to use conservancy district zoning to be more inclusive of wetland areas. The DNR has recommended that the model ordinance language, which currently allows the zoning administrator to immediately rezone an upland that has been incorrectly zoned a wetland, to also be able to do the reverse (immediately rezone an upland as a wetland). As of this writing, however, the language has not been included. It reads that where an "apparent discrepancy exists between the shoreland-wetland district boundary shown on Wisconsin Wetland Inventory and the actual field conditions...the zoning administrator shall contact the DNR to determine if the ...boundary as mapped is in error. If the Department staff concur with the zoning administrator that a particular area was mapped as a wetland, the zoning administrator shall have the authority to immediately grant or deny a land use or building permit." (DNR, 1997c:65).
Inland wetlands in unzoned towns are regulated only by the Corps Section 404 permitting process. As discussed previously, this effectively means that no protection exists for small wetland disturbances. Using the shoreland-wetland zoning ordinance to extend county authority to all wetlands (such as has been done in Dane County) would make the process more fair to all citizens in the county, because all wetlands would be treated in the same way.
Disadvantages
Extending authority through the shoreland-wetland zoning ordinance has some disadvantages:
Disagreement exists about the legality of extending county authority to protect all wetlands through the shoreland-wetland zoning ordinance. Some DNR officials believe that a county could do this through its ability to provide for the general welfare of its citizens. A DNR attorney contacted for this study indicated that NR 115 is clearly designed for only the shoreland-wetlands and attempts to go beyond the shoreland would probably exceed the county’s authority. Since all towns in Dane County have adopted the county zoning ordinance, this point has not been subject to a legal test.
Officials in unzoned towns may see this as a county encroachment upon their authority and may not support extending the shoreland-wetland zoning ordinance to include interior wetlands.
Eliminate the use of the maps as the basis for wetland zoning districts
Several stakeholders believe that the Wisconsin Wetland Inventory maps create as many problems as they solve, especially when the maps are used as the basis for establishing wetland zoning districts.
Instead of the current language of the Door County Zoning Ordinance, which reads: "Except as may be altered by zoning district amendment, the Wetland district boundaries coincide with the wetland district boundaries shown on the most recent version of the Wisconsin Wetland Inventory Maps," the following language could be substituted: "While the Wisconsin Wetland Inventory Maps provide a useful indication of where wetlands are located in the county, they are not absolutely reliable. Wetlands are dynamic, and may be different in size than the scale of the maps. Wetlands marked on the zoning map for the county provide an approximate location of wetlands. Building in wetlands is generally prohibited, except as provided in Section 2.05(4), and final wetland boundaries shall be determined by field verification by the Door County Planning Staff prior to the issuance of a building permit." Section 2.05 (pg. 12), Section 2.05(4), (pg. 20), Section 314 (pg. 49), could refer to wetlands, rather than wetland zoning districts.
Discussion: Is this strategy right for Door County?
Advantages
Disadvantages
This suggestion is supported by most of the staff in the Planning Department. Another way to reduce the frustration with the maps is simply to make better maps using a smaller scale. Several counties use the soil survey map to establish conservancy districts, and then regulate these districts in a fashion similar to shoreland-wetland requirements.
Adopt a general wetlands ordinance
Another approach to eliminating issues with the Wisconsin Wetland Inventory Maps is to adopt a general wetlands ordinance. This ordinance could assert the county’s right to protect wetlands under its general powers to provide for the public safety and welfare. The state of Washington requires counties and incorporated areas to adopt ordinances designed to protect critical environmental areas. Baltimore County, Maryland adopted a general ordinance to protect water quality, streams, wetlands and floodplains. The county’s regulations provide for preserving areas along streams, floodplains, wetlands, and erodible slopes, but does not establish these protections through zoning (Chesapeake Bay, 1997).
Calvert County, Maryland has established a goal of "no significant loss of wetlands." The county’s regulation, among other items, contains provisions against the filling of wetlands for single-family residential dwellings and establishes a minimum buffer zone of 50 feet of undisturbed natural vegetation of wetlands outside of the Chesapeake Bay Critical Area, which has more stringent requirements(Chesapeake Bay, 1997).
East Hanover Township in Dauphin County, Pennsylvania, developed a wetlands ordinance that requires all subdivision plans, land division plans, and building permit applications that result in a foundation inspection to include a wetlands determination. If a wetland is found, the applicant must demonstrate that activities will not degrade the water quality or wetland vegetation nor have an adverse impact on the wetland hydrological conditions. Should the Corps grant a fill permit, the townships request that the Corps require at least a 1:1 wetlands replacement ratio for acreage and function (Chesapeake Bay, 1997).
| Meridian Township in Michigan provides another example of a general ordinance protecting wetlands. Located on the northern edge of Lansing, Michigan, the township experience heavy development pressures. Concerned citizens noticed that Michigan’s Wetland Protection Law offered inadequate protection for small wetlands, even though Michigan had delegated Section 404 authority from the Corps. |
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In response in 1991, the township passed an ordinance that declared a short-term goal of no net loss of wetlands and a long-term goal of a net gain; protection for the small, pocket wetlands that were not covered by state law; 20 to 40 foot buffers between wetlands and development; creation of a detailed wetland inventory map; mitigation for all wetland losses; the appointment of a Wetland Board (Cwikiel, 1995).
It is reasonable that Door County could protect wetlands under a general wetland protection ordinance. A cursory review of Wisconsin counties did not uncover such an ordinance, but it may be worth pursuing. (Dane County protects all its wetlands under the shoreland-wetland provisions.)
Discussion: Is this strategy right for Door County?
Advantages
Disadvantages
Encourage towns to adopt county zoning
As described in Chapters 2 and 4, Door County protects wetlands in its zoning ordinance through the creation of wetland zoning districts. The zoning ordinance protects wetlands in the shoreland areas (lands within 1,000 feet of a navigable lake, pond or flowage and 300 feet of a navigable creek, stream or river) in all unincorporated areas of the county. Additionally, the towns of Baileys Harbor, Clay Banks, Gibraltar, Jacksonport, Liberty Grove, Sevastopol, Sturgeon Bay and Washington have adopted the county zoning ordinance. In these towns, the wetland zoning districts within the shoreland area and outside the shoreland area are regulated by the county. The towns of Brussels, Egg Harbor, Forestville, Gardner, Nasewaupee, and Union have not adopted the county zoning ordinance. In these town, county jurisdiction over wetlands is limited to shoreland wetlands.
Discussion: Is this strategy right for Door County?
Advantages
The advantages to this strategy include:
The major advantage to having all towns adopt county zoning is that wetlands would be protected in all unincorporated parts of the county in the same way. This would avoid the confusion that occurs in understanding how wetlands are protected in the county. In the inland portions of towns that have not adopted county zoning, the Corps are contacted for dredge and fill permits. With the exception of the town of Egg Harbor, which requires a 75 foot setback from wetlands, towns without county zoning rely on the Corps for wetland protection. As discussed previously, the Corps program is set up to automatically permit the filling of wetlands under one acre.
Disadvantages
The major disadvantage is a political one. Several stakeholders have commented on the different political orientations that separate southern from northern Door County towns. The southern towns were categorized as "more independent" and "more resistant to county control" than northern towns by several people interviewed for this study. Given this, it is not surprising that officials in towns that have not adopted county zoning who were contacted for this study all indicate that they would prefer to keep the county role in protecting wetlands the same.
Disadvantages, then, to this strategy include:
Political resistance may be reduced by meeting with town boards. It is not clear by the qualitative research done for this study that all town board members understand the county role in shoreland wetlands, the county role in creating wetland zoning districts, and the Corps and DNR involvement. One town board member commented, "We attempt to discourage development of wetlands in areas categorized as wetlands by the County of Door. The responsibility of enforcement, we [town board] feel lies within the county’s jurisdiction. Creeks and shorelines have been zoned for some time, again, there’s county enforcement." This comment suggests that the roles of the various governments are not clearly understood and that some conversation between the town board, town residents, the county, the DNR and the Corps about wetland regulations might help.
Also apparent is the frustration felt by at least some town board or planning committee members in towns without county zoning. One individual stated, "New development by prestigious people who have money seems to occur in wetlands, while the "little fellow" may be penalized for just walking across his property. New roads don’t seem to care much for wetlands either, for I’ve observed wetlands being decimated." This comment illustrates concern for equity in wetland protection, and also provides an opportunity for making an argument on behalf of county-wide protection, especially if the process is seen as fair to all areas in Door County.
Pass a state wetlands law
Chapter 2 described the current state statutes that protect wetlands. Unlike some other states, Wisconsin does not have a wetland protection law. Instead, wetland protection occurs in the state through the Clean Water Act–the water quality certification review for wetlands. The second major wetland protection is the shoreland-wetland ordinance mandating counties, cities and villages to protect shoreland wetlands. The result is that, despite the policy statement that wetlands should be protected, the state lacks a comprehensive law that protects wetlands.
This would not be a problem if the Corps had a strong program. Unfortunately, the Corps Section 404 program is destined to get weaker, not stronger, at least in the short term. One reason is that recent decisions by federal courts have limited the jurisdiction of the Corps. Most notably, incidental fallback (material that leaves the bucket of a backhoe, for example) can no longer be regulated by the Corps as a deposit into the wetlands. The courts have also held that isolated wetlands may not be protected under federal law unless interstate commerce can be demonstrated (previous to this decision, the Corps could assume interstate commerce if it was likely that migratory birds used the wetland).
| A second reason that the Corps program is likely to weaken in the short term has to do with continued budget constraints. According to Corps documents, inspections have decreased by 40 percent since 1992, and Corps staff have decreased by nearly 10 percent in the last five years. More troubling still is that orders to restore illegally damaged wetlands have fallen by over 60 percent since |
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| 1992 (Allen, 1999). Though the Clinton Administration advances a "no net loss" goal for wetlands, it has done little to stop the declining enforcement activities of the Corps. The EPA is not in much better shape to do enforcement: the agency has only 26 people nationwide in its technical wetland enforcement division. | ||
All of this means that states and local governments have to work harder to protect wetlands, since federal agencies are facing political and budgetary pressures to reduce enforcement efforts. Thus, it is perhaps time that the state legislature investigates a more comprehensive approach to wetlands. Wetlands have not been the topic of many bills in Wisconsin. However, a bill to establish compensatory mitigation and to provide more enforcement authority to the DNR in water quality certification is likely to be introduced in the year 2000. The Smart Growth Initiative may also help to protect wetlands in Wisconsin.
Discussion: Is this strategy right for Door County?
Advantages
A wetlands law in Wisconsin has the advantage of providing another way of protecting wetlands. Advantages of this strategy include:
Disadvantages
Drawbacks include:
This strategy is not likely to be successful in the short term, since the county has little influence over the activities of the state legislature. Still, it may be useful to start a dialog with state legislators on enacting comprehensive protection of the state’s wetland resources.
In sum, a variety of local, county, state and federal regulatory strategies may be pursued to better protect wetlands in Door County. The next section addresses non-regulatory strategies.
(Back to TOC)| Regulatory strategies are a necessary component to protecting wetlands. However, regulatory strategies may not be enough to protect critical resources. Increasingly, communities are turning to non-regulatory strategies as a way to complement wetland protection laws and regulations. |
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| Citizens as well as state, county, city, village and town government personnel throughout the country employ creative approaches that are effective at protecting wetlands and critical environmental areas. Indeed, non-regulatory strategies operate to fill in the gaps left by regulations. They have an added bonus–they tend to be appealing to many members of the public who feel that they are over-regulated. | ||
The remaining strategies offered in this chapter identify some of the more intriguing strategies found during the study.
Improve communication with the public
Many stakeholders noted that the public does not understand regulatory requirements for wetlands. As noted in Chapter 3, when a landowner applies for a building permit with the county, he or she may not know anything about wetlands, wetland maps, the setback provisions of the zoning ordinance, much less anything about the wetland zoning districts themselves. Additionally, the property owner may be mystified by additional requirements that he/she may be subject to under DNR or Corps authorities.
As part of this study, researchers visited the County, the DNR and the Corps offices that serve Door County residents. While each agency had information available to the public about regulations in its jurisdiction, no agency had substantial information about other regulatory programs and when those programs would apply. Instead, citizens were alerted in the written material that other laws or regulations might apply to their situation, and were sometimes referred to other agencies. Additionally, no agency had a comprehensive packet of information about wetlands and wetland regulations. The Door County Land Guide (1999) is a helpful booklet on land-use in the county, but provides only a brief description of wetland law.
In order to address this issue, several recommendations are offered:
Discussion: Is this strategy right for Door County?
Advantages and disadvantages to preparing a Citizen’s Guide and Landowner’s Guide
Developing a citizen’s guide to wetlands can be a very important first step in helping to clarify wetland protection efforts in Door County. A well-constructed citizen’s guide will inform the public about wetlands and their value; where wetlands are located in the area; what regulatory protections exist for wetlands and when these regulations apply; and, what to do if the citizen believes a wetland is located on the property. Finally, the guide could contain a flow-chart that documents the processes involved and where to get more information.
Developing a landowner’s guide to wetlands is a crucial component to alerting citizens to the possibility of voluntarily protecting the wetland resources on their property through bargain sales, conservation easements, donations or other means. Such a guide not only informs landowners of the significant economic and environmental contributions that wetlands make, but it also presents them with an array of options available to them should they want to maintain and preserve or restore wetlands on their property. The guide is based on the assumption that some landowners want to protect wetlands, and will do so either voluntarily or if provided with an incentive. Landowner’s guides have become a staple of aggressive wetland protection programs in Michigan and in Washington.
The major disadvantage to a citizen’s guide and the landowner’s guide is finding the resources to write it. However, several factors make preparing guides for Door County an easier task:
First, many sections of this study could be put into the guides with minor or no modification. Moreover, resources catalogued for this study could be used to help prepare a guide. Third, all agencies and several land trusts already have brochures and other public documents that could be incorporated into the guide. Fourth, completing one or both of the guides would not be an overly-burdensome task because Door County has wetland experts in the county who could assist in the development of the guides. Funding for projects like this in other locations has come from the EPA. The Wisconsin Environmental Education Program could potentially provide resources. Fifth, many excellent guides exist from other locations that could provide a model for the county. These are listed here and also in the reference section of the report:
Our National Wetland Heritage: A Protection Guide, written by Jon Kusler and Teresa Opheim and published by the Environmental Law Institute (1996). This guide is wonderfully written and takes the reader through chapters on understanding wetlands to what citizens and local governments can do to protect wetlands.
Living With Michigan’s Wetlands: A Landowner’s Guide written by Wilfred Cwikiel and published by the Tip of the Mitt Watershed Council (1998). This guide, now in its third edition, begins with a call for wetlands stewardship. Subsequent chapters discuss how landowners can manage their wetlands, what voluntary protection options are available, what federal, state and local regulatory requirements exist, and ends with a chapter on landowner assistance. This comprehensive and well-regarded guide is about 150 pages.
Wetland Regulations Guidebook, written by the Washington State Department of Ecology, (Publ.#88-5), in 1994. This guidebook provides citizens with a full discussion of the federal, state and local laws that may affect wetlands, when the laws apply to a citizen’s proposal, and what the laws and regulations require. The guidebook is concisely written, covering all this material in 40 pages.
A Citizen’s Guide to Land Use in Wisconsin, written by 1000 Friends of Wisconsin in 1998 is a short booklet that identifies the different jurisdiction and authority of various local governments as well as how to participate in land-use planning.
The Wisconsin Wetlands Association has written a Citizen’s Wetland Protection Handbook (1997) that would be an excellent place to begin a citizen’s guide. Much of the material is still current, and would only need to be tailored to Door County. It’s worth noting, too, that the Wisconsin Wetlands Association is working on a wetlands restoration manual that should be completed by the end of the year, according to staff at the association. In a similar vein, the Seattle Audubon Society has prepared The Wetland Protection Guide: A Citizen’s Guide to Wetland Protection Before and After the Bulldozer Arrives, (1995).
The National Wetlands Conservation Alliance prepared a guide that is available for duplication and comes complete with information about where to refine the language to fit the local regulations. This Wetlands Assistance Guide–A Template for Your Use is available to read on-line, but no diskette versions are available. Still, it would be a relatively simple matter to "cut and paste" some information from this source.
Finally, the Washington State Department of Ecology has extensive resources available to help county and local governments prepare citizens, local staff and officials for wetland protection. Two documents that potentially could be used as models include How Ecology Regulates Wetlands (1998) and the Wetland Regulations Guidebook (1994).
Increase public awareness of and education about wetlands
Closely related to increasing communication with the public is increasing public awareness of the importance of wetlands through educational and outreach efforts. Developing guides would help to communicate regulatory requirements, but also educate citizens. Wetland stewardship is occurring in many parts of the country, and is often facilitated by local and state governments as well as by environmental groups. Key components of educational and outreach efforts in Door County could include:
Discussion: Is this strategy right for Door County?
Advantages and disadvantages
| Public education was most frequently identified by stakeholders during interviews and focus groups as a promising strategy to improve wetland protection in Door County. Stakeholders agreed that many people don’t understand the economic and ecological value of wetlands, nor do they understand what is required of them under regulatory processes. Few citizens understand how they can voluntarily protect wetlands on their property. Just as important, key participants in wetland protection (farmers, realtors, local officials and landowners) need special attention. Given this, increasing educational efforts | ||
| is a critical component of any wetland protection effort in the County. Several examples of written materials can serve as models for preparing public outreach activities: |
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The National Audubon Society has produced a Citizen Action for Wetlands manual describing how citizens can be involved in wetland protection. They also have a number of examples of successful outreach efforts in Audubon at Work on Wetlands: A Record of Success Protecting and Restoring the Nation’s Wetlands 1990-1998.
The EPA publishes a quarterly report available on-line called The Volunteer Monitor which can be helpful when developing a wetland monitoring and/or assessment program. The agency also has materials for public outreach including, So, You Have a Wetland in Your Neighborhood... (brochure dated March, 1998) and a Wetland Walk Manual: A Guidebook for Citizen Participation.
Washington State Department of Ecology has an excellent training video on wetlands and a companion manual, Exploring Wetlands Stewardship: A Reference Guide for Assisting Washington Landowners. Similarly, the Chesapeake Bay Program, has Priorities for Action for Land, Growth, and Stewardship in the Chesapeake Bay Region, among other materials.
Improve communication between agencies
Better communication between agencies would make existing processes more efficient. Conversations with staff in all three agencies suggest that few formal intergovernmental meetings are held among Corps, DNR, county and local staff.
Establish a wetlands working group between agencies and a single wetlands contact person in the county
One way to improve communications would be to establish a wetlands working group composed of key staff in all governmental levels that could meet on a regular basis (perhaps quarterly) to exchange information. This working group could help develop public communication materials, provide public education and outreach on wetland protection efforts in the county, and also meet to share concerns.
Additionally, the DNR, the county and interested local governments such as the City of Sturgeon Bay may want to explore creating a single contact person for wetlands issues. This individual would lead the working group, but would also have primary responsibility for helping citizens understand the various wetland programs, initiatives, laws and regulations. This individual might best be placed in the County Planning Department, since the county was identified by most stakeholders as the best governmental level to serve as the focal point for wetland protection efforts.
Encourage Corps and DNR joint site inspections
One planning official from another county suggested that the DNR and Corps staff conduct some joint site delineations. He credited this approach with greatly reducing delineation discrepancies in his jurisdiction.
Discussion: Are these strategies right for Door County?
Advantages and disadvantages
Forming a working group and creating a single point of contact for wetlands in the county has a lot of advantages, including:
Disadvantages include the time involved in meeting and in creating the working group, as well as coming up with the resources needed to establish a central point of contact for wetland protection in Door County. A key issue would also be to resolve how that position would be funded (county resources, DNR resources, or some combination of governmental resources and grant funding?).
Encourage local governments to protect wetlands
If town officials in unzoned towns are reluctant to adopt the county zoning ordinance, they might be persuaded to adopt a town ordinance that affords protection to wetland resources. Egg Harbor, for example, has adopted a wetland setback ordinance. A survey of other towns, however, indicates that Egg Harbor is the exception–no other town official contacted for this study knew of any regulatory efforts underway to protect wetlands.
Town Board members who responded to the survey indicated that they would not like to see the county more involved in protecting wetlands in their town. They did not indicate that they are against protecting wetlands. So, it may be that town officials would be willing to initiate some town protections, especially if they had some assistance in identifying what they could do. Some particular issues identified from the surveys and the interviews might be handled at the town level. Towns could implement their own wetland zoning ordinances, or could address particular issues.
Develop a Wetlands Guidebook for Local Government
Many states and some counties have taken the initiative to assist local governments in wetland protection. This assistance comes in the form of guidebooks, training, and also in recognition programs. For example, communities in the Chesapeake Bay region receive recognition for their work in stewardship and in land-use protection. Guidebooks have been developed in several states with local governments in mind. A review of these for this study revealed several that would be worth emulating. These include:
Wetlands Protection: A Local Government Handbook, written by Marya Morris, a Senior Research Associate with the American Planning Association (1991). This 31 page booklet focuses on how local governments can protect wetlands through local controls, and also contains a nice section on federal and state programs.
Texas Coastal Wetlands: A Handbook for Local Governments is a very comprehensive and well-written book by Clair Randle. A major effort by the Texas General Land Office, this handbook gives an overview of what wetland management tools are available to local governments, outlines steps to develop a local wetlands plan, and provides a list of sources for more information. This 142 page handbook provides relevant information for landowners, citizens, local officials and groups interested in conserving or restoring wetlands. Although this is written for coastal wetlands, most of the information is appropriate for inland wetlands.
Chesapeake Bay Program, Protecting Wetlands: Tools for Local Governments in the Chesapeake Bay Region, and Protecting Wetlands II: Technical and Financial Assistance Programs for Local Governments in the Chesapeake Bay Region are excellent resources for helping local governments decide on the mix of regulatory and non-regulatory strategies for wetland protection. Chesapeake Bay has also created a Local Government Task Force to assist local communities in protecting critical wetland and other environmental areas. The Task Force has produced a Local Government Participation Action Plan to serve as a model for local governments.
Tip of the Mitt Watershed Council created Preserving Michigan’s Wetlands: Options for Local Governments in 1997 as a way of helping communities make choices about wetland protection. They have also developed a landowner’s guide and a book of case studies about wetland protection efforts in the Great Lakes Basin.
The EPA continues to promote grass-roots protection of wetlands. The agency published Protecting Coastal and Wetland Resources: A Guide for Local Governments in 1992 and established a wetlands toll-free hotline with lots of wetland information. The Department of Ecology and King County in the state of Washington collaborated on a guidebook, Designing Wetlands Preservation Programs for Local Governments: A Guide to Non-Regulatory Protection.
Discussion: Is this strategy right for Door County?
Advantages and disadvantages
A number of positive outcomes are possible:
As with many other non-regulatory approaches, the key disadvantage is having the time and staff to perform the work. It may be that the working group could decide to contact town officials as part of their duties; a citizens group discussed later in this chapter might also serve as a resource.
Coordinate wetlands protection with watershed/critical environmental areas efforts
Wetlands are important environmental resources. However, associated upland areas may be just as important to protect. Ideally, the county should seek to protect all of its critical environmental areas, with wetland protection being a part of that effort. Communities throughout the country are engaged in environmental protection efforts. The techniques are as numerous as the communities.
Here are two local government examples:
Discussion: Is this strategy right for Door County?
Advantages and disadvantages
Placing wetlands protection within the context of ecological systems protection makes a great deal of sense. Such a strategy could easily be incorporated into efforts by the Door County Stewardship Council to identify and preserve critical environmental areas. This strategy is also appropriate for Door County because most of the county is currently rural. The opportunity to protect environmental resources before they are developed is now in Door County, while the county still retains its rural character.
The disadvantages include overcoming governmental tendencies to sacrifice comprehensive, long-range planning for environmental protection to the short term needs for development and land-use. This is a common challenge facing officials in all levels of government. It can be counteracted by citizen involvement and interest in environmental protection. A second disadvantage is acquiring the resources to identify ecologically sensitive areas in the county.
Create a wetland advisory commission of key stakeholders
Internet and document review conducted for this study reveal a host of approaches for involving citizens in wetland protection. Citizen involvement was crucial to the success of local wetland protection efforts in the local communities, according to people contacted for this study. Citizens can help protect wetlands by monitoring permitting activities, by engaging in wetland education, by creating public information documents and increasing public awareness, and by fund-raising for preservation efforts. Some examples include:
| Common to these examples and others is the involvement of a range of key stakeholders. The most successful citizen commissions are composed of citizens who have different perspectives and who bring a diverse set of skills to the group. |
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Discussion: Is this strategy right for Door County?
Advantages and disadvantages
Public administrators have recognized the importance of citizens and governments working together for the betterment of the jurisdiction. This kind of co-production between citizens in Door County and state, county and local governments could afford greater protection of all important environmental resources. Should the county want to embrace multiple strategies for creating a more efficient and effective wetlands protection program, it is certain to need the help of its citizens. A wetlands (or more broadly, environmental) advisory commission could be of great assistance in these efforts, and could provide guidance to county and local governments.
The disadvantage to creating a commission is being able to sustain it over time. Volunteer citizen members may become tired or lose interest. Care must be given not to exhaust the group. In conducting an evaluation of grass-roots environmental efforts, the EPA found that a series of small wins was more motivating to citizen groups than nearly anything else. It would be wise, should the county decide to create a commission, to also devise a series of potential victories. For example, a first task could be creating a citizen’s or landowner’s guide to wetland protection. A second objective could be the development of wetland walks or other public activities to raise citizen awareness. A third objective could be intergovernmental coordination with local governments, and so forth. A long-term objective might be the establishment of a SAMP.
Door County has an abundance of citizens who are concerned about the future of the county. The county has many active environmental groups, including The Nature Conservancy, the Door County Environmental Council, the Gibraltar Preservation Council, and the Door County Land Trust. This assortment of groups could be a primary source of members for such an advisory commission. The added advantage is that the commission might, in turn, help coordinate the efforts of these groups, at least regarding wetlands.
Pursue acquisition or permanent protection of critical wetlands
Preserving wetlands through acquisition or some form of permanent protection is a very effective strategy. Land acquisition offers greater control, flexibility and the opportunity to partner with other governmental agencies and public or non-profit organizations. Several purchasing and protection techniques are worth considering:
Other alternatives exist to purchasing property or the rights to develop the property.
Discussion: Is this strategy right for Door County?
Advantages and disadvantages
Wetland acquisition programs are important components of effective protection of the resource. These techniques are increasingly popular because they compensate the landowner while also protecting the environment. They are generally viewed quite positively by the public, and were recommended by stakeholders who were part of this study. However, because many of these techniques take property off of the tax rolls or reduce the amount of property taxes paid, these programs need to be carefully reviewed to minimize the impacts on the remaining taxpayers. Should Door County decide to create a wetland acquisition program, it should offer a wide range of options to accommodate landowners and citizens. It should work cooperatively with land trusts in place in the county.
According to the Texas General Land office, the most successful wetland acquisition programs undertaken by local governments include the following components:
Sources of funding
Conventional funding
Finding funding to support a wetland acquisition program as well as other regulatory and non-regulatory strategies is challenging. During the course of this study, several ideas for funding emerged. One idea was to increase the property transfer tax and then use the proceeds to purchase wetlands or other critical environmental resources. Unfortunately, the current law does not permit the county to increase the real estate transfer tax, and only disperses 20 percent of the tax back to the county. While the county could choose to use its 20 percent to acquire wetland resources, it is unlikely to be sufficient to fund many purchases.
Another idea presented was to implement a lodging tax. This would generate additional revenues, since the county does not currently leverage such a tax. However, proceeds from this tax are dedicated to support tourism and imposing the tax has been unpopular among most lodging facility owners in the past.
A proposal to levying additional property taxes in Liberty Grove was soundly defeated this year. While the reasons for the defeat have not been fully investigated, it suggests that most residents may be unwilling to accept additional property tax levies in order to purchase development rights to property. However, this resistance may be overcome at the county level, if the levy was very modest and of a fixed duration. The county could also use part of its general fund to support a wetlands acquisition program, or it could consider taking a sales tax increase to the voters or applying a user fee to support acquisition programs.
Grant programs
In addition to these conventional funding mechanisms, the county could explore state and federal funding sources. Following are a few suggestions:
Private fund raising
Private funds can complement any of the funding strategies mentioned. The county can partner with environmental organizations, such as The Nature Conservancy, the Green Fund and the Door County Land Trust, to collaborate on private funding opportunities. One interesting strategy was used in Los Angeles, California to protect the Ballona wetlands. A coalition of environmental groups created a "foot by foot" wetland acquisition program. Individuals could purchase one or more feet of the wetland. In exchange for this contribution, the donor received a "deed" for the number of feet purchased. Conversations with the Ballona Land Trust staff indicate that this strategy has been a successful fund-raiser.
Discussion: how do we begin?
Applying for grants, setting up an acquisition program or seeking private funding is no small task. Door County may want to use a newly created citizen Environmental Advisory Board or a staff-based working group to accomplish some of this work. Should the county create a single contact person for wetlands, that individual might lead the grant application process.
(Back to TOC)This chapter has presented a wide range of regulatory and non-regulatory strategies that Door County may want to pursue in order to create a more effective and efficient wetlands program. The next chapter offers a way of evaluating which strategies might be the most useful and suggests some ways to get started.
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