By: Ann Boeholt and Camille Felkins, �鶹TV��վ Senior Environmental Managers

Adaptive management is often described as a best practice, but its value is most evident when projects face conditions no plan can fully anticipate. This case study — shared at the — illustrates how flexibility, collaboration and observation helped guide a project in a complex wetland system on Tribal lands.

Salmon, Sovereignty and Fish Passage

Pacific salmon have long been central to the cultures, economies and lifeways of Pacific Northwest Tribes. Over time, however, state highway infrastructure contributed to fragmented aquatic systems, limiting access to historic spawning and rearing habitats.

Since the 1990s, the Washington State Department of Transportation (WSDOT) has worked with Tribes and the Washington Department of Fish and Wildlife to identify and address fish passage barriers across the state highway system. This work accelerated significantly following a 2013 permanent injunction that established a 2030 deadline for replacing approximately 400 barriers — those expected to reconnect roughly 90 percent of the targeted habitat. Today, this ongoing, collaborative effort focuses on restoring connectivity within waterways that often intersect sensitive environmental and regulatory settings.

A Culvert, a Wetland and Changing Conditions

One such project along U.S. Highway 101 involved installing a fish‑passable culvert in 2025 to restore natural stream function. Adjacent to the site was a mosaic wetland system within the Quinault Indian Reservation.

Shortly after construction, a high‑flow event caused nearby Harlow Creek to overtop its banks. Water moved across the newly graded wetland, forming overflow channels and flow paths not anticipated in the original restoration design. While the culvert performed as intended, the surrounding wetland — newly planted and not fully stabilized — responded rapidly to these conditions.

These changes introduced challenges. Permit requirements included specific restoration and stabilization goals designed to meet water quality standards, while the wetland’s natural response made a rigid, prescriptive approach difficult to apply. In addition, the stream’s new flow path through the wetland meant that no in-stream work could occur until the following summer construction window. Any potential retrofit work within the wetland or stream would also require careful coordination, as these conditions coincided with the federal government shutdown in fall 2025.

Managing Complexity Through Collaboration

Responding effectively required close coordination among WSDOT, Tribal partners and multiple regulatory agencies. Additional constraints, including narrow in‑stream work windows and limited agency availability, reinforced the need for an approach that was both practical and adaptive.

Rather than attempting to force the system back to its original design assumptions, the project team proposed a flexible, adaptive path forward.

Letting the System Inform Solutions

In the near term, the team implemented minimal erosion‑control best management practices to protect the site while limiting additional disturbance. At the same time, they committed to ongoing monitoring to better understand how the wetland functions under post‑construction conditions.

Monitoring showed that the new overflow channels aligned with the wetland’s mosaic character. While the final design solution is still evolving, the longer‑term approach shifted toward stabilizing those channels within the floodplain — supporting ecological function and permit objectives while working with natural processes.

Together, these decisions reflect how adaptive management can support effective outcomes in dynamic environments by allowing real‑world conditions to inform design, permitting and long‑term performance.

Join Us at NAWM

We will share additional lessons learned from this case study during our presentation, “Implementing effective adaptive management to meet project goals in the face of unforeseen and changing conditions,” at the on Thursday, April 30, at 11 a.m.

If you are attending NAWM, we invite you to join the session and connect with us or continue the conversation on LinkedIn.

When Alexandra Davis volunteered to write her first National Environmental Policy Act (NEPA) document, she didn’t realize she was stepping into a new future. Before that, she’d been digging deep — literally. Trained as an archaeologist, Alexandra spent years unearthing human history at excavation sites in Malawi, Africa, contributing to discoveries featured in The New York Times.����

That one document marked a turning point, shifting her focus from uncovering the past to shaping the future. Now, as NEPA Services Lead at �鶹TV��վ, Alexandra helps navigate federal requirements that determine whether critical infrastructure improvements can proceed, analyzing everything from wetland impacts to community displacement to ensure Georgia’s transportation improvements protect both people and natural resources.����

Her work sits at the intersection of science, policy and community advocacy, influencing the infrastructure that connects Georgia’s communities. Recently, this impactful work earned Alexandra recognition as one of Engineering Georgia Magazine’s 2025 “35 Under 35 Women to Know,” an honor celebrating young leaders who are redefining the future of engineering.����

Q: Let’s go back to the moment you first said yes to writing a National Environmental Policy Act (NEPA) document. What were you thinking, and did you know then it would change everything?��

I was only 24 when I was offered the opportunity to work on NEPA documents, and honestly, at the time, I was just focused on staying employed and continuing to learn. It was right at the start of the COVID-19 pandemic, so job security was at the front of my mind. I figured if I could cross-train and make myself valuable to the team, I’d have a better shot at holding onto my position. It wasn’t an immediate career-defining moment. It took about two years of working in NEPA and three years at �鶹TV��վ for me to realize that this path was going to reshape my career in ways I hadn’t expected. And I’m so grateful I said yes to that opportunity.��

Q: You started your career excavating ancient remains in Africa. How did that path lead you to shaping policy through NEPA at �鶹TV��վ?

As an archaeologist, my work required not only excavating ancient remains but also being a strong technical writer and researcher, digging up information about the past, analyzing complex data and translating those findings into detailed reports. Those skills transferred directly to environmental consulting work. About a year after I started at �鶹TV��վ, my manager offered me the opportunity to begin authoring NEPA documents. I’ve always been eager to learn and grow, so I jumped at the chance. In addition to writing, I began coordinating with the Georgia Department of Transportation as a NEPA Analyst. It didn’t take long for me to realize that I had a real love for Environmental Project Management and, surprisingly, for the fast-paced, ever-changing nature of juggling multiple projects at different stages. While it might seem like a big shift from excavating ancient remains, both roles require attention to detail, problem-solving and a deep respect for our environment and history.��

Q: As NEPA Services Lead, what major projects or initiatives have you led since your promotion?����

Since my promotion, I’ve taken on leadership of all NEPA projects in Georgia, overseeing environmental compliance for more than 75 transportation projects. One of the most notable efforts has been managing and coordinating nine GDOT bridge replacement projects, which have required near-daily coordination and problem-solving. A major challenge on that effort was receiving Notice to Proceed later than expected and having to recover the schedule. This meant accelerating the environmental process for archaeology, history and ecology without compromising our quality standards. This experience showed me how important it is to build flexibility into our environmental review processes and maintain careful oversight. Beyond project work, I’ve also been leading initiatives within �鶹TV��վ’ Southeast region to strengthen connections between young professionals and current college students.��

Q: How do you balance protecting the environment with supporting the needs of the communities connected to it?����

On our larger GDOT projects, especially those involving new location roadways and potential displacements, it takes a lot of public involvement and coordination to address community concerns. In some cases, this has even led to redesigning project alignments to better serve the environment and the people impacted. Balancing these priorities requires constant, open communication between the design team, including the project manager, lead designer, traffic engineers and the environmental team. On the other hand, many of our bridge replacement projects tend to have minimal environmental impact and generally receive strong community support, which makes those collaborations much smoother.��

Q: You’ve been named one of Georgia’s 35 Women to Know. What do you hope stands out about how you lead and connect with others?��

My goal is to lead with kindness, empathy and flexibility. It’s important to me that the people I work with feel supported, heard and valued. I always want to be the kind of leader who makes time for questions, concerns, or just a quick conversation. I also believe work should be enjoyable. I truly love what I do at �鶹TV��վ and the people I work with, and I want my team to feel that same sense of purpose and enjoyment in their roles.��

Alexandra’s career may have started with a shovel in the ground, but her greatest impact may lie in what she is building — collaborative teams, thoughtful policies and space for more voices to shape the future. Her story reminds us that engineering is about more than equations or approvals. It’s about people, purpose and vision.����

Discover how our environmental services can support your next project, or follow Alexandra’s lead and join our growing team.��

Building a new bridge across the Mississippi River in the Baton Rouge area is not a new idea. The need had been there for decades, but getting beyond general conception has proved difficult, for any number of reasons. But today, thanks to a more pragmatic approach to achieving this monumental undertaking, a new Mississippi River Bridge (MRB)-building effort is taking those first critical steps toward becoming reality.

“Some of the attempts over the past 20 years have had bigger ambitions and scope and they were never able to get off the ground, either financially or politically,” says Kara Moree, CFM. “What we’re doing is concentrating on the early phases—selecting a location and getting the environmental documentation—to provide a foundation and build momentum for the project. This approach has been very successful in moving it forward.” Moree is the national director for NEPA & environmental compliance with �鶹TV��վ Technical Consultants and serves as the overall project manager. �鶹TV��վ was selected by the Louisiana Department of Transportation & Development (LADOTD) as the prime consultant to conduct an Enhanced Planning Investigation and Environmental Evaluation for a new river bridge, one of the most high-profile civil infrastructure projects in the state of Louisiana.

��Project staff members answer questions from the public about the new
Mississippi River Bridge at a community center meeting in April 2022.

As its first order of business, the �鶹TV��վ-led team was asked to identify approximately 30 possible locations for the new bridge. The project limits were set along 60+ miles of river so, at first glance, it did not appear to be a tall order, but they didn’t get too far into the navigation study before discovering just how many constraints the project would be subjected to. “There were a lot of places we couldn’t put piers in the river. There are anchorages and things of that nature that we needed to stay away from. We were also limited to a 2,000 ft maximum main span length. We consulted with the U.S. Coast Guard and spoke with river pilots and identified other restrictions and impediments. It was difficult coming up with 30 locations, but eventually, we did identify 32,” Moree says.

From there, the team took a tiered approach to narrowing that list down to a more manageable number. Two rounds of screening were conducted in consideration of the project’s purpose and need, which was informed and supported by traffic data and other analyses. “We also had to consider the environmental impacts. We had to determine if we would be able to get permits, whether it was for wetlands or levees or the Coast Guard. There’s also a lot of really big industry up and down the river, and of course, Baton Rouge has one of the busiest ports in the world,” she says. By taking a data-driven approach, the team, which included 13 sub-consultants, was able to back up their decisions with cold facts. This proved particularly beneficial when 10 preliminary alternatives were selected and presented to the public.

As in many areas of Louisiana, Baton Rouge is still dealing with the aftermath of Hurricane Katrina in 2005. Almost overnight, the area took in an additional 200,000 displaced individuals. One of the impacts of that growth was that the metropolitan area hit its projected 2030 traffic volumes 25 years ahead of schedule. A project of this size and potential impact is bound to raise the interests, and passions, of residents and community leaders. Extensive public information and stakeholder engagement efforts were particularly critical in keeping the project moving forward. The team also made quarterly presentations to a state legislative committee so that government and political influencers would be kept abreast of progress.

Although �鶹TV��վ is a national firm with 100 locations across the country, the MRB project has benefited from a decided home-field advantage. Both Moree and Maria Bernard Reid, NEPA specialist and deputy project manager were born and raised in south Louisiana. Although �鶹TV��վ is a multi-disciplined firm with the resources to complete a project of this magnitude from start to finish, it benefited from the specialized expertise of its two project leads. “We are not engineers—we’re environmental people. Everything we see, we see through the eyes of biologists and NEPA practitioners. The Federal Highway Administration, who will be reviewing our environmental document, really appreciates having that perspective informing our findings,” says Reid.

That advantage has resulted in what will be the first approved Planning and Environmental Linkages (PEL) document on a LADOTD project. The integrated and collaborative PEL approach asks project teams to consider environmental factors during the planning process, using data and analysis gathered during planning to enhance the environmental investigations and analysis. FHWA encourages its use as a means to save time and cost by minimizing duplicate efforts. “Going straight from planning into NEPA, we fully expect that all of our work will be brought forward. Having two environmental professionals leading that has been a very big plus in producing high-quality and approvable documents,” Reid says.

�鶹TV��վ is scheduled to complete its work on the MRB project in late 2024. A new governor and administration will be installed in January, and the team is focused on keeping the project moving forward and maintaining the state’s commitment. If all goes according to plan, it will soon be moving toward design and construction.

Published by Engineering News-Record (ENR)
On July 31, 2023

 

On May 25, the US Supreme Court issued a decision in the Sackett v. EPA case, a 14-year-long lawsuit over property rights and the legality of building on federally protected wetlands. All nine Justices agreed that the wetlands on the Sackett’s property should not fall under the jurisdiction of (CWA), permitting the Idaho couple to continue with construction of their new residence.

But there were substantial differences in the approach to the scope of the decision.

Justice Alito wrote the opinion for the five justice majority, which included Justices Barrett, Gorsuch, Roberts, and Thomas (note that Justices Thomas and Gorsuch prepared a separate concurring opinion).

Justice Kagan filed an opinion concurring with the judgement in favor of the Sacketts, but offered a more inclusive approach to the question of what wetlands should fall under federal jurisdiction. Justice Kagan was joined by Justices Jackson, Sotomayor, and Kavanaugh.

Background

The Sackett’s legal battle began in 2007, when they started earthmoving activities to prepare a 0.63-acre lot they owned near Priest Lake, Oregon.

The family received a notice from the Environmental Protection Agency (EPA) to stop work to avoid impacts to wetlands on the property. The EPA based their jurisdictional decision on their conclusion that the wetlands on the Sackett’s lot drained into a non-navigable creek that then led to Priest Lake.

The Sacketts challenged EPA’s decision, and the various cases worked their way through the federal courts, ending with the 9th Circuit issuing an opinion that there existed a “significant nexus” between the wetland on the Sackett’s property and Priest Lake. On May 25, the Supreme Court overturned that decision and essentially voided the “significant nexus test.”

Summary of the Decision

Justice Alito ruled that courts should apply a more stringent test, outlined by four justices (Alito, Chief Roberts, Scalia, and Thomas) in a previous case (Rapanos v. United States). Alito relied heavily on Justice Scalia’s opinion, in which he wrote that the Clean Water Act (CWA) applies to a particular wetland only if it blends or flows into a neighboring water that is a channel used in interstate commerce — generally referred to as a Traditionally Navigable Water (TNW).

The majority wrote that the text of the CWA defined “Waters of the United States” (WOTUS) as “geographical features” ordinarily described as “streams, oceans, rivers, and lakes.” The statute also clearly states that WOTUS includes wetlands that are “adjacent” to another WOTUS.

For decades, this meant that wetlands could fall under Section 404 even though they were separated from a TNW, provided there was some direct connection to that TNW. Thus, a wetland that was connected by even an ephemeral stream, through the greater stream network, eventually emptying into a TNW, fell under federal regulation.

Justice Alito, in adopting Scalia’s strict definition of adjacency from the Rapanos decision, wrote that wetlands can only fall under federal regulation if they possess a direct, relatively permanent connection to another WOTUS. Still, Alito seemed to indicate that to be adjacent, a wetland must be “indistinguishably” part of a stream, ocean, river, or lake.

Potential Effects

The US Army Corps of Engineers (Corps) and the EPA are expected to revise the WOTUS Rule once again. The rule recently enacted by the Biden Administration does not incorporate Justice Alito’s new, much narrower definition. The previous definition of WOTUS, one that has been in practice since 1986, also will not meet the new test in Alito’s decision.

It is clear so far that a wetland that is congruent with a stream or other regulated body of water will still fall under federal jurisdiction. It seems clear that a wetland that is adjacent to relatively permanent streams (intermittent or perennial streams) will also still be regulated, but that ephemeral streams would likely not be (ephemeral streams are not jurisdictional under the 1986 guidance). Furthermore, a wetland that is connected by a relatively permanent stream to a TNW should still be regulated.

The decision will most likely expand the definition of “isolated wetlands,” by removing from jurisdiction those wetlands that previously exhibited a “significant nexus” to another WOTUS. The attached diagram shows �鶹TV��վ’ interpretation of the decision based on information we have to date.

Note that state wetland regulations still apply until changed by the individual state administrations or legislatures.

The index below lists the WOTUS definition that is currently applicable in each state. This will likely change as the Corps and EPA establish new rules and guidance following the Sackett Decision.

Author:
Jim Kooser
�鶹TV��վ Senior Ecologist,
Wetlands and Natural Resources Management

�鶹TV��վ, O’Neill Service Group and partners are driving Salmon recovery in the Pacific Northwest.

State and local habitat enhancement dollars are funding the rebuilding of critical infrastructure to better serve fish and human populations. Salmon are a critical part of the region’s ecology and culture; �鶹TV��վ is positioned to be a part of its recovery.

Washington State Department of Transportation’s program to replace more than 400 non-conforming culverts beneath state highways is one of these programs. �鶹TV��վ is developing National Environmental Policy Act documents, Section 404 and 401 permit applications, performing quality assurance and environmental/material testing for these projects to restore hundreds of miles of historic breeding and rearing habitat statewide. Fish have already returned to stream habitat above the repaired culvert replacements. �鶹TV��վ is under contract for 35 culvert replacement projects in Washington.

As construction manager for King County, �鶹TV��վ is also removing old levees and reestablishing critical floodplain habitat along the region’s major rivers. The levee setback program is a major win for both salmon and the local communities, improving flood protection function and reconnecting habitat. Historic runs of chum salmon are returning to newly created channels like the one at Lones Levee Setback and Floodplain Restoration Project.

�鶹TV��վ looks forward to many years of important restoration in the Pacific Northwest.

Published by Engineering News-Record (ENR) – Environmental Management
On August 1, 2022