Integrated Training Area Management EA and Final FNSI

APPENDIX E: AGENCY COMMENTSThe following comments have been made by the U.S. Army Corps of Engineers, Fairbanks RegulatoryField Office addressing general concerns with the EA and ITAM Plan.Comments on Specific Sections of the EA.A review of the EA document by this office indicates that the evaluation of Wetland andWater Resources Sections are incomplete or inadequate.3.3 Wetlands1) USARAK does not have a current wetland permit to conduct military training inwetlands at Fort Wainwright, Tanana Flats Training Area, Yukon Training Areaor in Donnelly Training area as noted on page 30.2) USARAK classifies wetlands as “high-function” and “low-function”. It states thathigh-function wetlands include riverine, permanent emergent, semi- permanentemergent areas, riparian areas, and other sensitive wildlife habitats that lie inwetland areas. It does not state how the classifications were developed, or what“functions” are being reviewed for a given area. Wetlands reviewed under thisfunctional assessment were obtained from the NWI mapping.3) CE/EPA wetland definition not included in EA.4) Consideration should be given to the relationship between the CE technicalguideline for wetlands and the classification system developed for the Fish andWildlife Service (FWS), U.S. Department of the Interior, by Cowardin et al.(1979). The FWS classification system was developed as a basis for identifying,classifying, and mapping wetlands, other special aquatic sites, and deepwateraquatic habitats. Using this classification system, the National Wetland Inventory(NWI) is mapping the wetlands, other special aquatic sites, and deepwateraquatic habitats of the United States. The technical guideline for wetlands underthe1987 Corps of Engineers Wetlands Delineation Manual includes most, but notall, wetlands identified in the FWS system. The difference is due to two principalfactors:a. The FWS system includes all categories of special aquatic sites identified inthe EPA Section 404 b. (l) guidelines. All other special aquatic sites are clearlywithin the purview of Section 404; thus, special methods for their delineation areunnecessary.b. The FWS system requires that a positive indicator of wetlands be present forany one of the three parameters, while the technical guideline for wetlandsrequires that a positive wetland indicator be present for each parameter(vegetation, soils, and hydrology), except in limited instances identified in themanual.3.4 Water ResourcesThe EA does not address waters regulated under Section 10 of the Rivers and HarborAct and “other waters” regulated under Section 404 of the Clean Water Act._____________________________________________________________________________________________Environmental AssessmentUnited States Army Alaska, Integrated Training Area Management ProgramManagement Plan E-1