Operations - Regulatory (2010-05299-WMS)
MEMORANDUM FOR RECORD (Revised September 24, 2014)
DATE: July 28-29, 2014
SUBJECT: Gogebic Taconite - USACE/WDNR Field Review
1. St. Paul District Regulatory staff (Steve Eggers, Greg Larson, Bill Sande) participated in a joint field review of wetlands delineated within various parts of the Gogebic Taconite project site located in Ashland and Iron Counties, Wisconsin. WDNR staff participating in the field review included: Keith Patrick, Kyle McLaughlin, Pat Trochlell, Zoe McManama, Tom Bernthal, Tom Nedland. Others present included: Tim Myers (GTAC), Ann Michalski (Wetlands & Waterways), Jon Gumtow, Tim King and Neil Molstad (STANTEC).
2. The purpose of the field review was provide the regulatory agencies an opportunity to review sample wetlands areas that had been delineated to date in representative areas of the site and provide feedback and assurance on protocol and methodologies developed by the consultant team. The review area is approximately 4300 acres in size (based on the maps provided) and has been divided into a grid system for establishing transect locations. Each grid is approximately 1000 feet by 1000 feet (~ 23 acres) in size. All wetland boundaries are delineated and mapped with Trimble GPS units. Information provided in advance of the site review included:
* A summary table of wetlands to be field reviewed
* An overview map of wetlands to be field reviewed
* A map set of delineated wetlands to be field reviewed (Note: The wetland boundaries shown on the maps sets were provided for USACE/WDNR review of sample wetlands only. The wetland maps are not complete and should not be interpreted as final delineated upland/wetland boundaries).
* Wetland dataforms for wetland transects to be field reviewed
3. A review of the map sets provided indicated the majority of the wetlands that had been delineated to date were generally associated with a variety of surface water flows that ranged from discreet overland flow channels to perennial streams. The wetlands reviewed during our site visit appeared representative of the wetlands located throughout the project site and were generally considered “difficult wetland situations”. These wetlands include: slope wetlands associated with groundwater seeps, wetlands dominated by FACU vegetation (sugar maple), wetlands located on slopes with cradle/knoll topography, wetlands associated with or altered by logging roads and/or other disturbances, and wetlands located within in recent clear-cut areas. Primary indicators of hydrology were observed in the majority of the wetlands at the time of the site review. Secondary indicators of hydrology (microtopographic relief and geomorphic position) were also noted. Loamy clayey hydric soil field indicators were dominantly iron-based F3 and F6, although mucky-modified F1 was encountered. Although the land surface was vegetated, there was evidence of erosion. Sediment (slopewash) veneered many wetlands, complicating the identification of hydric soils. Generally, the soils lacked redoxomorphic features where landscape position and vegetation would suggest that field indicators should be present. Because the site includeds many “difficult wetland situations”, it was noted that the consultant team appears to have adopted a conservative approach to capture all potential wetlands areas using best professional judgment. There was general consensus among the USACE/WDNR staff that the procedures and methodology employed to evaluate the entire site for wetlands was satisfactory and there was a high degree of confidence of those employed for this effort considering the difficulty of the site.
4. We discussed that there should be a procedure developed to account for numerous wetlands areas that are too small to delineate individually and do not fit the mosaic approach outlined the regional supplements. The consultant team was going to propose methodology for USACE/WDNR review.
5. The consultants asked about concurrence with the delineation on the site; whether it would be acceptable to submit delineation reports as they are completed within portions of the site and whether the agencies would need to visit each wetland. The consultants indicated they had divided the site into several areas based on watersheds. However, a map showing the “watersheds” was not provided and it was not clear what they were based on. We indicated that we agreed with the approach to review delineations as they are completed for each area and suggested that a map of the entire site with all of the areas (watersheds) identified be provided.
6. There needs to be consensus on determining exceptional versus high ratings for wetland functional assessments using WRAM and agencies need to provide the company’s consultants guidance on vegetation species list for WRAM (Tom Bernthal/Steve Eggers).
7. Gtac (Tim Myers) indicated that it is their intent to complete all fieldwork this year. However, it was not clear whether Gtac would be requesting Corps concurrence with the wetlands delineation in advance of a permit application.