East Side Wetlands

Developing Methods to Establish an Urban Wetland Mitigation Bank on Youngstown's East Side (December 2009)

The city of Youngstown, like many “endangered” industrial cities in the Midwest, has lost significant population over the past half-century and has begun to seek methods to creatively manage shrinking while identifying an appropriate and smaller footprint. Youngstown has seen its population decline by more than half since 1960 due to the effects of deindustrialization and a large out-migration of residents. This decline in population has resulted in an excess of vacant land, as well as land that was never developed, particularly throughout the east side of the city. Under the guidance of the Youngstown 2010 Comprehensive Land Use Plan, the city has committed to a plan of “right-sizing” and adaptively reusing large tracts of abandoned land or land that was never developed on the city’s east side.

The abundance of abandoned or unimproved land presents the city with a number of liabilities, but also a unique opportunity. As many properties located on the city’s east side are located in poorly drained areas that exhibit relatively flat terrain, saturated soils, wetland vegetation, and hydrology, these properties may provide the city with an opportunity to restore, enhance, establish, or preserve wetland resources, and sell mitigation credits, by establishing a wetland mitigation bank. A mitigation bank would allow the city to sell mitigation credits to developers who cause adverse impacts to wetland habitation and are required by law to replace this loss of wetland functions. The creation of a mitigation bank and the subsequent sale of mitigation credits to developers is one of the avenues that can be taken to satisfy compensatory mitigation requirements for impacts to wetland resources caused by development. Fittingly, Mahoning County currently has insufficient space available for wetland mitigation, and any mitigation required for development projects must be done outside of the county. The development of a mitigation bank will allow the city to adaptively reuse large tracts of undevelopable land while selling mitigation credits and creating recreational and education resources for the public.

The following report outlines the steps necessary to establish a 112-acre wetland mitigation bank on the city’s east side, and is divided into four sections. Section 1 provides an introduction and background to the project, and an overview of wetlands and existing mitigation banks in Ohio. Section 2 contains the process that was used to select the 112-acre Mitigation Bank Target Area on the city’s east side. Section 3 focuses on recommendations to the city for acquiring the necessary property to establish a mitigation bank, preparation of the site for construction of wetlands, and completing the necessary legal steps to establish a mitigation bank in the target area. Section 4 provides a detailed analysis of compensatory mitigation banking rules and regulations.

All property necessary for the development of a mitigation bank should be acquired prior to beginning the process for establishing the bank, but only after the city has committed to constructing the bank. However, the city may choose to construct a smaller mitigation bank within the target area on a 20-acre property currently owned by the city, and begin selling mitigation credits from that bank. This property is referred to as the Miltonia Avenue Site throughout this report. The city may then use those funds to acquire the remainder of the property within the target area to expand the mitigation bank.

The city will need to hire a consultant that specializes in environmental construction services to complete a mitigation plan and the application process, and to assist in the construction of the mitigation bank. Assuming that a total of 50 acres of wetlands will be constructed within the target area, and then used as mitigation credits that will be sold, the city can expect to incur costs of approximately $378,386 for property acquisition and demolition of structures, between $112,000 and $177,500 for engineering and planning, and between $750,000 and $1,000,000 for construction, for a total cost of approximately $1,240,386 to $1,555,886. The cost per acre, or mitigation credit, will be approximately $24,808 to $31,118. If the city chooses to first construct a mitigation bank on the Miltonia Avenue Site, the costs incurred will be approximately $112,000 to $177,500 for engineering and planning and $150,000 to $200,000 for construction, for a total cost of approximately $262,000 to $377,500, assuming that 10 acres of wetlands will be constructed. The cost per acre, or mitigation credit, would be approximately $26,200 to $37,750 under the latter scenario.

The number and price of the mitigation credits that will be available for sale once the bank is established and functioning cannot be accurately determined at this time, although an analysis of existing mitigation banks throughout the state of Ohio revealed that nearly 2,000 mitigation credits are currently available, and range in cost from $12,000 to $36,000. However, no mitigation banks currently exist in the Mahoning River Watershed. This is a key point as most developers will be required to mitigate within the boundaries of the local watershed, and the value of the mitigation credits to be sold upon the U.S. Army Corps of Engineers District Engineer’s approval of the final mitigation banking instrument will be determined by the current market, which currently includes no mitigation banks. Therefore, a mitigation bank on the city’s east side may provide mitigation credits at a higher price than those from other banks that are not unique to their local watershed.

The final report was completed and submitted to the city of Youngstown in December 2009.