Integrated Training Area Management EA and Final FNSI

APPENDIX F: RESPONSES TO COMMENTSCOMMENTRESPONSEU.S. Army Corps of Engineers, Fairbanks Regulatory Field OfficeEA CommentsUSARAK does not have a current wetland permit to conduct militarytraining in wetlands at Fort Wainwright, Tanana Flats Training Area, YukonTraining Area or in Donnelly Training area as noted on page 30.Accepted. Text corrected inSection 3.3.USARAK classifies wetlands as “high-function” and “low-function”. It statesthat high-function wetlands include riverine, permanent emergent, semipermanentemergent areas, riparian areas, and other sensitive wildlifehabitats that lie in wetland areas. It does not state how the classificationswere developed, or what “functions” are being reviewed for a given area.Wetlands reviewed under this functional assessment were obtained fromthe NWI mapping.CE/EPA wetland definition not included in EA.Consideration should be given to the relationship between the CEtechnical guideline for wetlands and the classification system developedfor the Fish and Wildlife Service (FWS), U.S. Department of the Interior, byCowardin et al. (1979). The FWS classification system was developed as abasis for identifying, classifying, and mapping wetlands, other specialaquatic sites, and deepwater aquatic habitats. Using this classificationsystem, the National Wetland Inventory (NWI) is mapping the wetlands,other special aquatic sites, and deepwater aquatic habitats of the UnitedStates. The technical guideline for wetlands under the1987 Corps ofEngineers Wetlands Delineation Manual includes most, but not all,wetlands identified in the FWS system. The difference is due to twoprincipal factors: a. The FWS system includes all categories of specialaquatic sites identified in the EPA Section 404 b. (l) guidelines. All otherspecial aquatic sites are clearly within the purview of Section 404; thus,special methods for their delineation are unnecessary. b. The FWS systemrequires that a positive indicator of wetlands be present for any one of thethree parameters, while the technical guideline for wetlands requires that apositive wetland indicator be present for each parameter (vegetation, soils,and hydrology), except in limited instances identified in the manual.The EA does not address waters regulated under Section 10 of the Riversand Harbor Act and “other waters” regulated under Section 404 of theClean Water Act.Asphalt is noted as a structural material for erosion control that can beused in stream crossings.Wetland Checklist addresses an impact threshold on wetlands that doesnot exist.Water Resources Checklist does not address Section 10 and Section 404impacts to waters of the United States (waters not regulated as wetlands).ITAM Management Plan CommentsAccepted. Text clarified inSection 3.3.NotedAccepted. Text clarified inSection 3.3.Accepted. Text clarified inSection 3.4.NotedAccepted. Text clarified inchecklistAccepted. Text clarified inchecklist_____________________________________________________________________________________________Environmental AssessmentUnited States Army Alaska, Integrated Training Area Management ProgramManagement Plan E-14