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commencement. We can orchestrate these activities with the Corps with Kehn Construction's and your <br />approval. <br />Permit amendments should include:, 1) Review and adjustment of project compensation phasing; and 2) <br />Adjustment of interim requirements to reflect current operational status and better suit projected needs and <br />operational criteria. The current plan requiring creation of temporary wetlands is not cost effective. To the <br />extent feasible, mitigation plans should be modified to create permanent compensatory wetlands at a rate <br />commensurate with disturbance. Such an adjustment would be included in a reduction of mitigation <br />requirements. <br />Finally, with the 2004 compliance inspection forthcoming, this would be a good time to address wetland <br />issues. Of concern is the current condition of mitigation sites, that could be viewed by the COE as non- <br />compliance with approved permit conditions. Proactively addressing this situation should minimize the <br />potential for adverse regulatory action. <br />In summary Kehn Construction's current wetland permit conditions represent an unfair regulatory burden. <br />This conclusion is based on the following facts: <br />• Our preliminary observations of current site conditions indicate that the original jurisdictional <br />wetland delineation is grossly inaccurate; <br />• Ongoing operations are moving slower than anticipated and therefore are out of sync with the <br />permit's operational requirements; and <br />The ratio of jurisdictional to compensatory wetlands is inordinately high and can be reduced <br />significantly with permit amendments that include a reasonable monitoring program. <br />A real and significant potential for Kehn Construction to reduce wetland compensation and economic <br />burdens has been identified. With the adoption of specific monitoring requirements, obtaining Corps <br />approval to reduce compensatory wetland mitigation requirements from 129.5 acres (1:73:1) to 74.8 acres <br />(1.1:1) is highly likely. Re-delineation of jurisdictional wetland has the potential to further reduce <br />compensatory wetland replacement by about 50% (_34 acres). Avoiding compensatory wetland <br />construction costs typically ranging from $1,500 to $5,000 dollars an acre have the potential to realize <br />compliance savings ranging from $139,00 to $325,000 dollars over the course of the project. Re-delineating <br />and amending the permit constitutes about 10% of the lower-end cost savings. Monitoring compensatory <br />wetlands can be expected to cost around $5,000-per year in current dollars for an area of this size; a <br />minimum of one year of monitoring is required with 2 to 3 years being common. Compensatory wetland <br />savings would also offset water storage pond design costs, which provide the client with a profitable long <br />term land use. <br />It is our recommendation that Kehn Construction proceed with re-delineation and amendment of the <br />existing permit. Attached is a rough estimate of the costs associated with these activities. Please advise <br />either Wayne (303-770-9788) or me as how you wish to proceed with this project. We look forward to <br />assisting you in helping Kehn Construction meet its ongoing business needs and goals. <br />Sincerely, <br />David Wileden <br />w/attachments <br />David Wileden @303-256-8459 <br />dwileden a~abitatmanagementinc.com <br />