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SUMMARY & RECOMIVIENDATIONS In Sugnet's opinion, approximately 1,264 acres of jurisdictional wetlands and other waters of the U.S., including appro�cimately 228 acres of wetlands, approximately 1,034 acres of open water, and appro�mately 46,2461inear feet of stream, are present within the study area. Sugnet also identified two areas that may qualify as fen wetlands, however, further investigation and soil analysis is needed to confirm that these areas actually meet the physical paratneters used to define a fen wetland. This would require at least one day of field work by a qualified wetland ecologist as well as lab analysis of the fen soil. The USACE, in coordination with the US Fish aiid Wildlife Service (USFWS), has instituted a regional condition which may revoke certain Nationwide Permits when fen wetlands may be adversely iinpacted: Regional Conditions for Revocations Specific to Certain Geographic Areas e. Fens: In Colorado, nc�tiornvide permits No. 1, 2, 4, 6-11, 13-19, ? 1-25, 28-31, 33-36, and 39-44 are revoked for activilies in these regio��ally irnportarrt aguatic resources. Fens are c�efrned as iveticrnds which are characteri=ed by ti��ater logged spongy ground and contc�in (in all or part) soils classrfred as histosols * or n�iner•a/ soils ��ith a histic epipedon*. To determine i��hether thispr•ovision applies, the entire N�etland mzist be examinedfor the presence of histosols or histic epipedons. *Histoso/s have 40 centimeters (16 inches) or more af the upper 80 centimeters (32 inches) an organic soil mczterial (or less over bedrock). Organic soil material has an organic carbon content (by weight) of 12 to 18 percent, or more, dependzng on the cicry conlent of the soil Histic epipedons have n 20 to 60 centi�neter-thick (8- 2�1 irsches) organic soil hori�on that is at o�� near the surface of a mzi�eral soil. Histosols aszd histic epipedons are ��idely recogni=ed as organic soils formed by slow accunzzt/ation ofplant debf•is in lvaterlagged situatiorrs ia�here it cannot decompose. (Mare information on histosols can be obtained fr•om the U.S. Department ofAgriczdture, Natural Resotrrces Conser��t�tion Service publications on Keys to Soil Taxor�omy and Field Indicators of Hydric Soils in the UfTited States. (US.4CE 2002) However, according to a USFWS Inteinal Memorandum dated June 8, 1998, certain limited impacts to fens may be allowable under an Individua1404 Perinit if the applicant can demonstrate that "every efFort has been made to avoid and minimize impacts" to the special resource and "there is no practicable alternative for nonwater dependent activities." This guidance stems from the US Environmental Protection Agency's (USEPA) Section 404(b)(1) Guidelines, specifically, section 23010(a). Fut�thermore, any impacts to fen wetlands must provide mitigation in the form of "[fen] restoration of nearby and in- kind fens that have been previously degraded but which are recoverable (e.g., tluough elimination of grazing or restoration of hydrology)." Therefore, additional field work may also be required to identify a suitable fen restoration area within a local watershed, which may or may not be present (USFWS 1998). �� 555 Rivergate Lane, 81-101 Durango, CoTorado 81301 Ph.970.259.9595 Fax.970.259.0050 wwwsugnet.com