Research

INTRODUCTION

Once regarded as wastelands, human development damaged over 50% of global wetland ecosystems (Davidson 2014). Now, humanity increasingly recognizes wetland ecosystems as sustainable building blocks for society (Finlayson and Horowitz 2015) and identifies direct dependence between wetland ecosystems and human well-being (MEA 2005). The evolving human-wetland relationship describes a growing awareness of interdependences between humans and the environment. Natural resource management is increasingly expected to benefit society and nature (Sanborn and Jung 2021). In 2001, the National Research Council’s report “Compensating for Wetland Losses Under the Clean Water Act” paved the way for the 2008 U.S. Army Corps of Engineers (USACE) and U.S. Environmental Protection Agency (USEPA) mitigation guidance preferring wetland mitigation banking to both singular onsite, offsite, and in-lieu fee restoration projects (Hough and Robertson 2009). This policy change was partly due to the economy of scale in which restored wetlands generate mitigation credits, and performance standards validate restoration outcomes (Ruhl and Gregg 2001). Federal wetland mitigation policies have evolved and shifted through decades of trial and error, critiques, and challenges (Hough and Robertson 2009). We discuss wetland mitigation performance standards in the United States within an environmental governance context, highlighting them as integral components of the dynamic evolution to improve wetland mitigation outcomes. However, especially in a regulatory context, we stress the dynamic nature of this evolution. We must note the pendulum-like forces at play, especially considering the U.S. Supreme Court’s Sackett vs. USEPA decision (2023) limiting the authority to regulate wetlands based on a decidedly unscientific measure: a surface water connection. Although based on this decision, there are up to tens of millions of hectares of once federally regulated wetlands under the Clean Water Act that will no longer be under USACE permitting jurisdiction (CRS 2016), the mitigation process remains unchanged, only the definition of a federal wetland requiring mitigation has changed. This ruling does not affect a state’s ability to implement or enforce state regulations to protect isolated wetlands.

Environmental governance recognizes laws and policies drive agencies and organizations to make regulatory decisions (Bennett and Satterfield 2018), albeit with findings and interpretations changing over time. Under the United States Clean Water Act, mitigation is required when impacting federally protected wetlands above a threshold (USACE and USEPA 2008). This mitigation process is overseen by the USACE, with the USEPA acting as the enforcement arm of the regulatory process (Hough and Robertson 2009). Although the mitigation process’s legal, policy, and partner frameworks are driven by federal legislation, in reality, the state agencies share regulatory roles in practice as part of the Interagency Review Team (IRT). This team consists of representatives from federal and state agencies that oversee mitigation project compliance (Robertson et al. 2018), establishing a formal space for federal and state collaboration.

The IRT approves wetland bank performance standards site-by-site and is tied to ecological goals and objectives. The growth of the wetland mitigation banking industry created a market-based system where ecosystem services are bought and sold through credit and debit transactions (Robertson 2006, Vaissière and Levrel 2015, Hough and Harrington 2019). Performance standards play an integral role in regulating credit transactions, as projects must achieve their performance standards before receiving their final credit release, and the mitigation banker can transfer long-term stewardship (and liability) to a successor (Vaissière and Levrel 2015). Therefore, performance standards fulfill many functions within the wetland mitigation process, mimicking an environmental governance framework with public-private and private-social relationships (Lemos and Agrawal 2006, Armitage et al. 2012, Rudolph et al. 2012, Richardson and Lefroy 2016). Regulators rely on the private industry to accomplish the on-the-ground or practical component of mitigation (public-private relationships). These actions benefit society by generating ecosystem services (private-social connections). In both scenarios, performance standards act to verify the wetland mitigation process. We note that private industry and regulators alike have biases and preferences, and no two bank sites are the same, which lends itself to differing performance standards across areas and states, especially in the absence of research data. Private industry and academia also directly and indirectly contribute to developing performance standards based on practical experience and research results.

Performance standards emerge as the balance between management and ecosystem conditions (Fig. 1). Their role synthesizes management and ecological expectations within a complex social-ecological system framework (Hossain and Szabo 2017). Identifying and establishing a space for the interaction of management and ecological systems increases the sustainability and resiliency of a complex system (Gain et al. 2020). Post-restoration monitoring plays a crucial role in adaptive management (Failing et al. 2013) and triggers management actions to ensure wetland ecosystem development remains on track. Incorporating these perspectives shifts focus away from command-control thinking and toward a more flexible management perspective (Cote and Nightingale 2012, McCool et al. 2015), where post-restoration monitoring drives management actions (Richardson and Lefroy 2016). However, the absence of long-term research data makes it difficult to definitively select the most effective, meaningful, and essential standards for evaluating site conditions and determining “success.”

As many researchers question the ability of performance standards to be used as indicators of restoration success (NRC 2001, Cole 2002), numerous challenges exist in developing appropriate performance standards. Identifying predictable, linear trajectories in short time frames (Zedler and Callaway 1999, Nevel et al. 2004, Stefanik and Mitsch 2012) and limitations on time, energy, and resources often lead to a reliance on simplified assessments (Cole and Shafer 2002, Veselka et al. 2021) and lack of pre-restoration data (Becker et al. 2022). In addition, assessments primarily rely on structural criteria that might not correlate to accurate functional evaluations (Mitsch and Wilson 1996). More in-depth functional and structural reviews often occur after the requisite monitoring period (Millikin et al. 2019, McPherson et al. 2020, Noe et al. 2022). Although most assessment criteria are vegetative-based (Matthews and Endress 2008), management and administrative measures beyond an ecological context are needed (Martin et al. 2005) to ensure that project compliance equates to program success (Matthews and Endress 2008).

Performance standards play a crucial role in verifying wetland mitigation, but the history of their use is dynamic. Before the 2008 Final Rule, federal regulations loosely described wetland mitigation (Hough and Robertson 2009), so the USACE districts established performance standard criteria requirements, often in coordination with other state and federal agencies (Robertson et al. 2018). Whereas setting national performance standards is unachievable because of the diversity of wetland types, state-developed performance standards can effectively evaluate mitigation project outcomes (Nevel et al. 2004, Stein et al. 2018). A multi-level governance structure is a form of adaptive management (Olsson et al. 2004). Although federal policies identify national goals, state governments may be better suited to address regional aquatic resource management issues (Owens and Zimmerman 2013). In addition, the interpretative fluidity of federal policies denotes the critical role of state and local permitting laws and ordinances (BenDor et al. 2008). Although mitigation policies have been critiqued for ineffective standards (Clare et al. 2011) and ecological outcomes are questioned (Mitsch and Wilson 1996, Zedler 1996), continued emphasis on post-restoration monitoring and performance standards demonstrates wetland mitigation is dynamic.

This research investigates performance-standard determination within the regulatory community, focusing on the state agency perspective. Although federal legislation drives wetland mitigation, understanding the involvement of state agencies will provide a more comprehensive view of management. County-level ordinances and state statutes create a “geographic patchwork” of wetland mitigation policies (Robertson 2006), and performance standards are known to differ between projects (Breaux and Serefidden 1999, Streever 1999). Rather than a project-by-project basis, we aimed to use a 50-state strategy to investigate the extent of state involvement in the performance-standard formulation and differences among state mitigation strategies. We explore decision-making drivers and differences in performance standards across the United States. We hypothesize that state legislation is the primary driver of decision making and utilize an inductive approach to identify other key drivers. We use our findings to discuss performance standards as an opportunity to improve wetland mitigation management and ecological outcomes.

METHODS

To investigate state agency involvement in performance standards development, we followed a generalized procedural pathway of (1) data acquisition, (2) thematic analysis, and (3) result visualization (Fig. 2). We utilized a mixed-method approach using semi-structured interviews, legislative database reviews, and internet searches to collect qualitative data. State wetland program managers, enforcement agencies, or other appropriate respondents participated in the semi-structured interviews through email and phone surveys. Along with the interview outreach, a legislative database review and internet searches revealed state legislation and program documents used by agencies to establish performance standards and monitoring protocols. We collected data for online database reviews and interview outreach from October 2021 through April 2022.

Semi-structured interviews

We identified points of contact from a state’s wetland program, environmental enforcement agency, or another appropriate state entity and contacted potential respondents via email and telephone. Using a semi-structured interview approach, we prompted respondents (one per state) with two open-ended objectives to (1) verify if the state has adopted legislation describing performance standards and (2) provide a list of example performance standards. Beyond the initial prompts, we asked follow-up questions to clarify responses or obtain additional information regarding program implementation. We imposed no time limitations on the interviews and allowed respondents to explain and expand on answers openly. Interviews generally lasted < 30 minutes. We summarized all responses and stored shared documents we received during the interview. We directly transcribed performance standards instead of summarizing them to maintain language integrity. We developed a project database using Microsoft Excel to store data collected for each state for future analysis.

Database review

We systematically reviewed state legislative policy and language regarding wetland mitigation performance standards. We searched the “Legal Information Law Institute” database maintained by the Cornell Law School, starting with the keywords “State Name,” “performance standards,” and “wetland mitigation.” Next, we substituted “performance standards” with “performance criteria” and added “credit release” and “monitoring.” Then, we replaced “wetland mitigation” with “compensatory wetlands” to capture all relevant legislation. We used similar keywords and search criteria for an internet review to search for other publicly available documents that states may use but are not incorporated into legislation. We recorded a description of returned results, including the policy citation and a description of the policies.

Thematic analysis

After obtaining all responses, we conducted an extensive data review, including data cleaning to standardize all responses. Next, we conducted thematic coding to investigate reoccurring themes and identify irregularities among all responses. Thematic coding is a type of pattern recognition for qualitative data where themes or topics emerge that contribute to the larger research question (Tashakkori and Teddlie 2010). Themes included similarities or irregularities of management approaches across states. We utilized an inductive approach and identified themes after data collection and initial review (Patton 1990). We followed a five-phase process, including (1) familiarizing ourselves with data, (2) generating initial codes, (3) searching for themes, (4) reviewing themes, and (5) developing and naming themes (Braun and Clarke 2006). Findings were summarized by state (Appendix 1).

We synthesized data from the interviews and legislative database review to develop a ranking scheme to describe the level of state legislation adopted. We created four legislative ranking categories (None, Some, Moderate, and Extensive). A state classified as “None” had no reference to wetland mitigation. A state classified as “Some” mentioned wetland mitigation at a minimum but also may include a definition for mitigation-related processes and terminology. A state ranked as “Moderate” required monitoring but did not require specific attributes to be monitored. A state classified as “Extensive” achieved the highest-ranking category, extensively explaining monitoring and performance standard criteria by explicitly stating criteria or referencing specific characteristics to be evaluated.

In addition to legislative rank, each state received a classification for the type of guidance document obtained during this study. We classified the guidance document’s authorship into two categories based on the listed authors of the record: (1) state authorship only and (2) state and federal authorship. We further refined the groups into sub-groups (general guidance, technical reports/studies, templates) to briefly describe the guidance document’s purpose, layout, and content. A general guidance document assisted internal regulatory decision making and was a guide for staff members. A technical report served less as a guide and provided extensive background information to help inform decision making. A template document reached beyond the regulatory agencies and instead helped guide private industry stakeholders to complete required documentation such as a Mitigation Banking Instrument. We classified all states where we did not encounter a guidance document as “None.” Although these states may still use guidance documents, we did not encounter any during this research.

Finally, we reviewed performance standards from interviews and guidance documents. We classified performance standards using a tiered approach to organize each performance standard by system, type, and category. The system described the landscape features such as riparian, upland buffer, wetland, etc. Next, we classified standards into abiotic, ecological, or administrative categories. Nested within each type (abiotic, ecological, and administrative), we established categories to classify performance standards further. Abiotic categories included hydrology, soils, area, habitat features, topography, delineation, erosion, geomorphic, physiographic, debris, and water quality. Biotic categories included vegetation, functional assessments, wildlife, hydrology, biogeochemical, condition, geomorphic, supplementary, and threatened and endangered species. We noted performance standards as incremental if criteria changed over time of the monitoring period and were grouped into temporal categories (e.g., baseline or initial, interim, and long-term) depending on the passage of time from the start of the mitigation project. Administrative categories included reporting, waters of the United States, monitoring period, funding, general, design, land protection, and others. As evidence of difference, we used Pearson’s chi-squared goodness of fit test to compare the distribution of states among categories for the legislative rank (none, some, moderate, extensive), guidance document type (none, state and federal authorization, or state authorship only), and performance standard types (abiotic, biotic, and administrative) (α = 0.05). After we found a significant result, we conducted pairwise comparisons to determine where differences exist.

RESULTS

A representative from all 50 states responded to our survey request. The largest percentage of respondents belonged to the Department of Environmental Protection/ Quality/Management/Conservation/Control (60%), followed by the Department of Natural Resources (16%; Fig. 3). Other respondents included the Water Resource Department (3%), Fish & Wildlife (2%), Department of Highways/Transportation (2%), Department of Health (1%), Department of Ecology (1%), Geologic Survey (1%), Conservation Commission (1%), and Department of State Lands (1%; Fig. 3). The most common job title of respondents was Administrator/Manager/Director/Supervisor/Chief (50%), followed by Wildlife Biologist/Biologist/Ecologist/Scientist (18%), Coordinator (12%), Wetland/Wetland Mitigation Specialist (12%), Enforcement/Policy (2%), Engineer (2%), or Other (1%).

Legislative standards

We synthesized results from the semi-structured interviews and legislative reviews to determine the complexity of state-adopted legislation regarding performance standards for all 50 states into four categories: None (18), Some (18), Moderate (7), and Extensive (7; Table 1). We found that states classified as “None” defaulted to the USACE to establish performance standards. Although the state may participate through the Interagency Review Team, there was no formal guidance from the state level. We found a difference in the distribution of states among legislative rank categories (N = 50, X² (df = 3) = 9.68, p = 0.02), with more states classified as none and some than moderate or extensive (p = 0.028).

Guidance and technical documents

In addition to a legislative rank, we obtained guidance documents for 35 states and classified them by authorship: federal and state (18) and state only (17; Table 1). The remaining 15 states may still use guidance documents, but we did not obtain them during this study. Although these documents helped guide decision making, the content of the papers varied. Records that had both federal and state authorship consisted of general guidance documents (12), template documents (4), and technical reports/scientific studies (2), compared to only state-authored documents, which consisted of general guidance (13) and technical reports/scientific studies (4). All states classified as “extensive” legislation also used guidance documents (Fig. 4). Sometimes a state may have no legislative requirements and instead use a guidance document to drive decision making. We tested the distribution of guidance document authorship (none, federal and state, and the state only) among states. We found the proportion of states did not vary by guidance document authorship (N = 50, X² (df = 2) = 0.282, p = 0.869).

Performance standards

We obtained example performance standards for 24 states and classified these states by the type of criteria used: ecological only (6), ecological and abiotic (14), and ecological, abiotic, and administrative (4; Table 2). We found the proportion of states differed by performance standard types (N = 24, X² (df = 2) = 7, p = 0.0302). More states use ecological and abiotic criteria compared to ecological, abiotic, and administrative criteria (p = 0.0184). We obtained 327 example performance standards across all states and habitat types (Table 2). These standards and their percent of occurrence include ecological (71.3%), abiotic (23%), and administrative (6.1%). Vegetation criteria were the most common performance standard across all categories, representing 60% of all performance standards. Abiotic hydrologic characteristics were the second most frequent, representing 5.8% of all performance standards.

We found that abiotic criteria, such as soil and hydrology, often use USACE definitions (Table 2). Other approaches use baseline or reference conditions to determine hydrology thresholds. States sometimes use physical topography standards to ensure hydrology requirements, such as the topography of tidal marshes, as evidence of tidal frequency and duration. Some criteria overlap the abiotic and ecology categories. For example, hydrologic and geomorphic characteristics could be considered ecological or abiotic depending on the measured attribute. Geomorphic assessments that rely on macroinvertebrates as indicators receive an ecological classification, whereas assessments that use bank slope profiles are abiotic. Examples of administrative criteria included securing long-term funding, reporting, and documentation of an IRT site visit, land protection agreements, or placement of “Do Not Mow” signs.

Our inductive approach revealed the following themes as irregularities or reoccurring topics encountered during data collection: (1) customized performance standards for local conditions, (2) the use of incremental standards, (3) the use of functional assessment scores, and (4) different standards for mitigation mechanisms (restoration vs. preservation; Appendix 2). States often customize vegetative standards based on wetland type or known invasive species. States grouped performance standards by Cowardin et al. (1979) wetland types, such as palustrine scrub-shrub or forested, or ecosystems specific to the state, such as cypress swamp or bottomland hardwood. For example, woody vegetation requirements for stem density may decrease as time since restoration increases. Another emerging theme included splitting performance standards by mitigation mechanism (restoration vs. preservation). Only a few states implement preservation-based performance standards, but many others inquired and wished to adopt them to hold preservation sites accountable. Although the indicator or attribute being measured was often the same between mitigation mechanisms, the level that constituted success differed. For example, preservation sites are expected to sustain conditions throughout the monitoring period, while restoration sites are expected to improve as time since restoration increases. Preservation performance standards include vegetative buffer community assessments, soil and hydrologic abiotic features, wetland biotic features such as vegetation community and forested basal area, functional assessment scores, and native amphibian richness and abundance.

DISCUSSION

The results of this study demonstrate the diverse roles and extent of state involvement in determining performance standards. Although we hypothesized state legislation would be a defining feature, we discovered a combination of collaboration, legislation, and guidance documents cumulatively drive decision making. Although federal regulations steer wetland mitigation procedures and federal agencies oversee the process, some states have developed legislation in addition to national regulations. The participatory spectrum summarizes state and federal agencies’ roles in determining wetland mitigation performance standards. A combination of legislation and guidance from state and federal regulators converge and collaborate through each state-specific IRT (Fig. 5). The spectrum is meant to reflect the diversity among states as some state performance standards are driven by federal agencies, whereas others may be more driven by state agency supervision.

Our results show guidance documents play a prominent role in decision making. In contrast, we did not anticipate the importance of guidance documents, as numerous respondents during the survey referenced guidance documents without being prompted by the researchers. Beyond examining authorship, the guidance documents’ content showed diverse management approaches. Whereas states differed in legislative rank distribution, they relied similarly on guidance documents. Although legislation and guidance documents help formulate and organize performance standards, performance standards are often finalized through a collaborative process, and the determination occurs on a project-by-project basis. Collaboration and negotiation between all participants on the IRT serve as the final checkpoint for establishing standards. The IRT serves as a collaborative entity where both state and federal agencies share regulatory responsibilities and oversee the final approval of performance standards. However, guidance documents can help formulate and tailor performance standards to general conditions within the state.

Our results show that most performance standards are vegetative-driven, partly because of data-collection’s ease, consistency, and interpretability, echoing the results of other studies (Cole and Shafer 2002, Matthews and Endress 2008). Although performance standards differ by USACE district (Robertson et al. 2018), our study demonstrates that performance standards will also vary by state. In addition, some states during the interview process noted that local municipalities have legislation and standards that guide wetland mitigation at the local level, and these local ordinances can vary within the same state. These findings suggest management occurs through a cascading hierarchy of local, state, and federal oversights. Our results confirm that wetland mitigation policies appear as a “geographic patchwork” nationwide (Robertson 2006). More than two decades after performance standards were questioned for being uncoordinated and inaccurate measures of success (Streever 1999), our findings demonstrate the type of criteria being used has only evolved marginally and is still based mainly on vegetative criteria. Progress in incorporating metrics beyond vegetative standards has been slow, indicating success based on the ecosystem functions and services these mitigation banks are meant to replace are still not wholly directly measured. Although many states during the interview process emphasized the need to determine performance standards on a project-by-project basis, most mitigation bank sites still have similar criteria for post-restoration evaluation.

Numerous states declared performance standards should be selected on a case-by-case basis and believed this flexibility inhibited adopting official performance standard guidance in legislation. However, some states have incorporated this flexibility into their guidance document recommendations. Although the state may have a set of predetermined or routine standards, other monitoring criteria can be used, primarily when mitigation reflects unique ecological environs, such as those found around tidal or vernal pool wetlands. This flexibility and customization demonstrate a shift toward a more balanced management approach. If it is generally accepted that performance standards should be flexible and tailored to specific projects instead of homogenized, perhaps a shift in semantics is needed. Utilizing “success criteria” instead of “performance standards” may move expectations of standardization into customizable interpretations. During our interview process, many states referred to performance standards as success criteria, suggesting a change in semantics is already occurring.

Another potential barrier to integrating performance standards into legislation is a lack of leadership or responsibility at the state level. Frequently, there was a within-state discrepancy regarding the authority to respond to our survey request, the state laws, and how the laws are enforced. This inconsistency shows a potential lack of leadership or central coordination at the state level. Identifying a central coordination agency with strong leadership is needed to guide governance management techniques (Watkins et al. 2013, Sapkota et al. 2018). In addition, there were a few cases where there was a discrepancy between the semi-structured interview results and the legislative database review. The survey respondent would say the state had no legislation regarding performance standards. Still, during our database review, we found legislation. On the opposite side of the spectrum, many state agencies would collaboratively respond to the survey, which shows inter-agency collaboration at the state level. Beyond cooperation and communication, respondents noted a lack of resources, time, staffing, and other practical reasons as barriers to developing performance-standard legislation.

Although performance standards are designed to validate restoration outcomes and demonstrate restoration actions that replace lost wetland functions, numerous challenges exist in balancing management expectations with actual ecological results. Incorporating natural ecosystem fluctuations into the management environment is challenging. Current strategies to balance management expectations and restoration outcomes focus on integrating resilience into the performance standards structure. For example, incremental standards based on time since restoration helps track progress and site development over time. Second, using reference sites may be beneficial in establishing an appropriate threshold for success (Sueltenfuss and Cooper 2019). Still, we encountered few mentions of reference sites to develop performance standards during this study.

The roles and responsibilities of state and federal governments are difficult to determine and are often a larger philosophical question of governance. Environmental appreciation has grown in the past 30 years, and agencies use interdisciplinary approaches to tackle complex issues (Perring et al. 2015). As the scale and intensity of negative environmental consequences grow, a parallel shift must occur to adopt more collaborative and larger-scale governance structures. Governance can improve the transboundary approach to managing large, complex social-ecological systems. Social scientists increasingly recognize social factors as constraints to restoration project success (Sapkota et al. 2018, DeAngelis et al. 2020). Wetland mitigation has begun to adopt a governance approach and balance management expectations with restoration outcomes. Although wetland mitigation is a federally regulated process, diverse management approaches exist nationwide. Legislation, guidance documents, and direct collaboration between state and federal agencies influence decision making and real-world outcomes.

Regarding applications within the United States, neither regulators nor researchers know the implications for Sackett vs. USEPA (2023). Therefore, we consider what this means for developing future wetland mitigation success criteria. The importance of state regulators in the IRT process becomes more significant considering this decision. Because the term nexus has been redefined in a federal sense to a surface water connection, it becomes even more apparent the role researchers must play in understanding and developing performance standards for hydrological connections. We must articulate the importance of developing success criteria to ensure wetland mitigation banks meet the no net loss mandate of functionality in the Clean Water Act despite the judicious non-scientific ruling on what constitutes a wetland worthy of Federal protection. In a joint conservative and liberal justice comment, they argue that the majority’s new definition was incorrect and will significantly affect regulated waters. We note that during the interview process, at least two states mentioned although the state may not have legislation, local municipalities filled the gap with their legislation and approach.

How the court’s opinion affects mitigation performance standards and success criteria will be interpreted by IRT teams at the state level and will still use scientific reason to develop these criteria. However, as knowledge and coordination promote sound management, we have created a database, including guidance documents, success criteria by themes, and interview results, allowing users to explore the data collected and processed during this study (Appendix 1, 2). As interpretations of the Sackett (2023) judgment are incorporated into mitigation performance standards, our database will enable users to search data organized by state, success criteria, and legislative rank to ensure meaningful ecological function and service. A significant barrier to state agencies developing and implementing management protocols is a lack of resources, including funding and time. National surveys like this help reveal national trends and help states learn from other programs. We created this database to allow practitioners to explore different state approaches to wetland management and to serve as a starting point for developing their management actions.

CONCLUSION

Future research should continue to investigate the role of Sackett vs. USEPA (2023) in the decision making in the wetland mitigation process and its influence on the success of wetland mitigation projects. If a surface water connection is the defining characteristic of a wetland, incorporating stream mitigation performance standards would be beneficial as many stream and wetland mitigation programs overlap at the regulatory enforcement and project level. The merging of these standards could help protect against the dewatering of wetland success requirements. We also must consider what this means regionally for mitigation, as Carolina bays, playas, prairie potholes, and vernal pools may not have a role in preservation if not found jurisdictional. Although many argue for a separation between research and policy, the Federal definition of a wetland requiring a surface water connection will significantly affect regulated waters. We respond with a call to researchers to deliberately take time to disseminate information about the hydrologic connections in groundwater so states might invoke their right to protect the public health of their communities.

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