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HomeMy WebLinkAbout2003.10.28 - Wildwood Development Montana Addition Comment Letter from Dixie LlewellinOlympic Wetland Resources, Inc. Dixie Llewellin, Principal Biologist T v'x n ntt es 4r Mt '-V "U 1A-,: l lt ek "1,11 ontana :Addi Fl I IOWA like to comiient %On Liz. Berman proposed cottage haus iig development '- M the North Beach area. Please find the enclosed map ofthe fiindi3ngs for a previous Wetland Delineation for an adjacent property (Block 7 Montana Addition, dine 2002). The Bernian project ismearthe Junsdictional buffers 6f-a Class II wetland associated with the Quimper Wildlife Corridor: This project is technioally outside the legal buffers or flood plains but it is still in a close elevation grade with the main channel of one of the most important drainage basin in the City of Port Townsend. I do know that the City has the option of expanding buffers to further protect wetlands functions, such as stormwater retention. Downslope flooding has already been documented along this corridor. I can verify this increasing problem as a downslope property owner of 23 years. As a wetland biologist I have conducted wetland delineations along the Quimper Wildlife Corridor for the Jefferson Land Trust the City, and numerous private clients. The main F intent for the corridor is to reserve the continuity ofthe land as much as '' "... p ty possible with uninterrupted areas for wildlife. In general, houses and buildings within co nstitute. cmaLl-percentage of the overall lot size. The "Wildwood Development" plans to take maximum advantage of the allowable lot coverage with buildings. This project is not congruous to the intent ofthe Quimper Wildlife Corridor or the surrounding community. Liz Berman also owns other parcels in the immediate vicinity (Parcel #972 -901 -602 and 972 -902 -102) as indicated on the enclosed map. .Are. there limits to the expansion of the cottage development "2 Although she does not °admit to future plans to develop those parcels it would be very easy to fill those parcels once the infrastructure is in place. r I also have concerns with the on site plans. One concern is the underground garage El proposed for the project. I have observed many instances near drainage basins where disturbed or excavated areas end up as ponds (especially in the Clallam soil group). I find it an interesting'notion that this garage may end up as a pond during high water years. The plan also specifies the retention ofthe trees within the interior or courtyard of ovathecottages. The trees on this flat block of land are thin and spindly and will probably not withstand the winds once the remaining support trees are removed and soils are disturbed. Is there a revegetation component required with this plan? 1 I have reviewed the Cottage Housing Ordinance (17.16.05 0) implemented by the City of Port Townsend (1 /02). Was the original intent of adding cottage housing to the Port Townsend Municipal Code to provide economic housing alternatives in urban areas. within walking distance to city centers? 1 know-that one of the main cottage developments" used as a model for this plan was in Langley (Whidbey Island). This development is near the city center. In contrast the Berman project is an expensive housing alternative (not even intended to be low- income housing) in a rural part of to where cars would be required to do most commuting and shopping_ My recommendations for the "Wildwood" development w:' s d be t reevaluate the building density adjacent to an important drainage corridol 11 wetland. and associated 100 -foot buffers. Due to the poor drainage of s and existing downslope flooding that already exists building density should be decreased and a re- vegetation plan within the open space should be required. Extra measures should be taken so that the stormwater plan is adequate and enforced to retain all stormwater so it does not enter the wetland and contribute to additional downslo flooding. 1, r,. Pe r yr yr; 1 = uvt1F/ t 4 Thank you for the opportunity to comment on this - project. „J ti's Sincerely, Dixie Lleweliin Cc North Beach Neighborhood Association Daubenbergers pe; SM% Sh Berman ProjectOlympictWbmas, ! . NTS 3 4rL y {7Y14W5Msko Pwbmsend, Wa98368 October 2003 360385-6432 Job* l a a is lifle: Findings Map Scale: Sheef Olympic Wetland Resources, Inc. Betty Jo Lawrence 3" =100' 49th and Hendricks 856 50fh Street Port Townsend wA December 2001 4 Port Townsend, WA 98368 Clienf Jefferson County Land Trust 360 385 -6432 P.O. Box 1610 lab # 0974 PortPort Townsend, WA a a is lie' (pP -ice 112,S/OZ- 49th Street A4 t A3 A2 Al A5 100' buffer A6 if Shed Data Point #2 100'buffer 100' buff r xtticti ng en reloe AS lie' (pP -ice 112,S/OZ- 49th Street Montana AdditimBlock 15 Lots 1-8 and Block 16 Lots f4 Pod Tbvvnse4 )M V .00 V 4 S I St Street 50th street Mapped Wetlands (City ofPort Townsend Wetland -Map 1995) MiWand Edge From Survey November 30, 1999 100' Buffer Fromr, WWandEdge indicated on mad s time. Note: -A"ll roads Sept S do not exist but are only platted at thiexcepI. heridan). Lines indicated on this map are for general planniing purposes only and do not represent a formal delineation. Gippic Wifland Re;ourcz, Inc.. TiRe! Wetland Edges 5 (012 V,=100, sheaf and RuMrs Date 856 50th R.reef M. Townsend, WA 98368 Dec. 1, 1999 A-1 Ciaims 360 38542 RO. Box 17449' Oh# 00999 . 3eagle, MA 98107 It Bloe 1 Lots 1-8ifI- kllk 5fantanaAddit4 and Block 16 tots t4 Port T, S end 11 WMAII 1100. V V 5 1 st. Street 50th Street M- ped We B s (c-4 of-. P.-oft Townsend Wedand Map I w-s-) WW and Eke From Swmey November 30, 1999 I OO'BuMr From WWand Edge Note- 'i A-H.roads (except Sheridan) inAcated on map do not exist but are only platted at flu-s time. Lines indicated on this'map are for general planning Purposes only. and do not represent a formal delineation. A We Olympic Mand Ruwurcz, Inc... W Iwd Edges =100' Bu. ban 856 501 ieef d rs ec. 1, 1999PoRWnsend, WA 98368 aim i . C-- -. - . . . D 360 3854432 A-1 jR0. Box 17449 Seattle ANW 98107 lob # 99-00-93 r- H— n Lisa Palazzi, Principal 2W Fourth Ave. But suite 416 " - i (?IMpia. WA 9850? 205) 534.0346 Report Rile Number: E92 -0060 (EES42323.010). Report'Subject:. Critical -drainage corridor north.,of 49th " Street. ' Location: The corridor evaluated runs approx. from the intersection Hendricks and ,49th. St. east' to the Chinese Gardens.:.-, Client:; Port- Townsend- Public'Works `. This- letter report Is provided. to •briefly describe findings of a recent evaluation: of the -above defined drainage corridor. 'Various portions of •the _ site were wi_sitea on three separate - occasions'.'.. The i ntent was .to. deefine' at `- least the cen- terli.ne of- the ,corridor,-' ;acid" i4 some areas:• to define - its."br. 6,id extents-as rei.ting to already existing:City. street•- easements..•-.: Field flagging :arid •evalua.tion 'was done by Li ga .PalazZi, -and Doug "Mason. Initially ;_. -SCS soil -maps, 'Port `Townsend wetland. maps, .aerial: - photo's, 'and to a limited'degree - topography maps were.consulted'to identify.• areas of- concern on each site. Brief site visits were' used to: verify, -refute, or add to existing' informition'. No•soil pits were evaluated, so soils discussions are based solely on SCS soil mapping of the areas evaluated SOIL SERIES 'DESCRIPTIONS: 31ie following de'sc"riptiona are based on -the SCS soil.. mapping and expected characteristics-, of the -:soil - '.series ,as mapped.'. Please- refer. to the-following section ;`for- site:spec fic iTifnrmat .on.` according =to .the :Te£fe son •County = . soil siiruey,.' three _ "soil "series=•'are ,_mapped'' alo g-_ the: d-corridor:: 1) the A'6ew" iiji'•- xoam `aassified. _as • a fine =sil ty;= mixed, mesic Oql raqualfi Fine -sil mixed;" me sic. "'pic :Ochraqualf,': generallyty meaning •the.: soil has'.Ian. Ari ' i .lic . (clay): horizon: and greater than .-35x __base sat at on,.'.(alf.),= 31-4 expected .to. hae. v a- seasonal' high water table within 18 2) the Clallam gravelly-sandy loam (classified as a loamy - skeletal, mixed, mesic Entic Aurochrept') 3) the. San. Juan gravelly sandy loam . (cl'assified ' as coarse -loamy ..over sandy or sandy skeletal; mixed, mesic: Pachic..Xe'rumbrept') Additional soil -seri.es .such 'as the. Swantown,'.- Wapato, . and. Mukilteo_ -muck -are mapped around .the' Chinese Gardens.:' .But since- they do not-affect the majority of the drainage- corridor, -will, not•be-desdribed further. AGM SERIES .',. The Agnew si1t.-loams- are 'moderately.. deep, somewhat poorly- dtained: saii'sformed 'in. shallosd:'-glaciolacustrine . sediments: overlying laminated glacial till.- .--"these' : soils.: are` often -associated with "wetlands.: - Generally.; _the_ uppersoilsare.silt loamy grading to_'silty clay loams with depth.':Mottl.ing is expected ar'3 inches depth and gleying at 9 inches. depth -- .evidence of seasonal water almost to :the surface for extended- periods. .'Below•approx. 30 inches (in the_ C :horizon),'. gravel content increases. abruptly, from <5% in the surface, soils to". between 10'and'50% in the subsoils.. The. lower horizons are highly laminated and 'very hard glacial. till.. Average soil percolation rates. iii the upper,9 :i.nches are expected to be moderate .'(0.'672 inches per hour),. decreasing to moderately dour (6.2 -0.6 inches per hour) below 9.inches•depth.;: = . The Agnew soils 'are'generally,suitable -for: some crops and pasture with the main limitation being seasonal wetness (a:perched water.table) at 12 to 24. inches .of. the 'soil. surface -. (aqu)•,'. has a pale -colored, low base .saturationthan50X), surface- horizon "(bchr) .' is otherwise: typical ..(typi.c) , has ''a" mesic _ - temperature _regime. (mean annual temperature ranges from 8° to..15° C .(477 -.'590:k), no.. specific' oe =-.(mixed), and -is greater than 18% slay -and less:"' minera1bgic s.urc t;hav 15X sand (or coarser).._by weight (fine- silty) Loamy - skeletal.; .mixed; .mesic Entic' Durochzept, generally meaning the soilhas-minimal horizon development (ept and erotic); has a pale- dolored,-low base- saturation surface horizon (ochr), has an silicate- cemented subsurface. layer Our), has:a mesic temperature regime- (mean annual temperature ranges from 80 to 15" C (470 '- .59° F), .has no specific mineralogic- source -(mixed), .texture of the. fine fraction- is .loam and' coarse fragmerit- -.content is greater than 35X (loamy- Skeletal).-.. Coarse- loamy.`over: sandy or sandy skeletal_; mixed, .mesic•'. Pachic Xerumbrept; :.generally meax i rig the. , soil.-ha' limited ' horizon'. development ept)," has- :a'-dark colored ,sui'iace ;horizon'Aiith a =low base aatzirati~on {umbr) ;:.hasdevelopedunderciiniate- conditions..of.'wet wimters =aud droughty:summers- (xer) -, :and'. has a deep•:,rgFeater :than 50". cm)- dai:k =col tired;:. =sur €ace - horizon =(gachic), has a' mesj.c temperature `.regime -meeant ;aririval .temperrature- =ranges'- from 8° to ' 15° -C "(47 -_ 59 °.:F) .no':specific mineraiogic.saurc °(mi_xed).; -b"_."1.5-50% .sand; less than i.BX. clay,.:aiid Rossbly gxeat.er' than 35X coarse £zagments -( coarse -loamy over sandy or . sandy skeletal)..' - - - - inches depth.'. The. main limitations for onsite'septic and'stormwater treatment are related toboththeminimaldepth :to 'the hardpan •and. seasonal .wetness. Sail waterpercolatingthroughthese 'soils "will modown; The' ve laterally in the soil rather thanseasonalrhighwater.table and /or the shallow .till layer limits theamountofsoil 'available :ta effectively treatt- stormwater or septic effluent. CLALLAH• SERIES—` : The :Clallam. gravelly sandy 16ams ar''e --oderatel • : - y.- deep,'..wel - drained .'soils. foried::in glacial ill. :: Th'ey 'are. usually. found -`6r uplands,.: 'slopes ranging Y from-0-30Z... ': The ,'surface soils -:are, generally grayish -brown to dark grayish- • ' brown• gravel] y 'saxidy .looms ._ = They• have a weakly- cemented •glacial till layer 'at _ 20 -40- inches :depth that will - restrict vertical' soil:' percolation to samedegree ; =: •. " . Average soil permeability is - expected to moderate (0.6 =2 inches per hour) above the cemented "till and very, slow (less than 0.06 inches per hour)-in thetilllayer. t-A. seasonal.-perched water. table is not expected;: the till..in: theseareasmust -be more fractured. 'However, the- "soil is expected to be satun:the periodically• during the .rainy season "and the majority of '-soil water will ' percolate .;laterally,::' . r The : Glallam soils originally developed finder ' a' forest; .biit more than' half ofthemappedacreagehasbeencleared.and is now used for: "pasture,.'garderis," orchards and'hoinesites.'..The 'primary limitations are related- -to'shallow soil - depths. Storin_water will prcoae into soil.readily in. undisturbed areas; but will'. move laterally act -oss the-till layer, surfacing in adjacarit riraiiiageaand=low =lying areas: Septic'system desidepths •and•. fluctuatin .. will be Ii.mited. by minimal soil, g _seasonal high "water. SAN`. JUAN The San.J S uan ERIES sandy-- very de ep.,• somewhat exce_ ssivV ely drainesoils• farmed in d` glacial. -The surface soils are "generally `dark- coloredgravellysandy'ioams.. Soil texture becomes coarser with-depth, gravelly loamy "coarse sand. and gravelly coarse sand. p grading to Average soil 'per'meability is "expected. to be rapid (6 -20 inches per hour) throughouut . ' - . The San :Juan•`soUS are' i.s used for farmland -, hayland pasture; woodland or-. homesites _with few limitattions:. '.The "pri ry.'limitation .for se tic drainfields " or'`stormwater.: f c.i i ti-es are' "related to =poor.' filtering capacity due' to `rapidpercolationrates :and :rel'atively low surface" area in "saridy"soils.."'• If housingdensityis. moderate .=to` xiigh, =.=community: sewage. systems or alternative `septic . desigxis - are rec"onimended, to reduce- patential,-of: water sup} ily:,coi tami.z ation by fir.. - '- _ • '. . SITE •_SPECI' FIC :`CHARACTERISTICS _ - • _ - - The western*' eh(' 'drainage' 'corridor ; initiates`'at • .• - Hendricks just north of theiitersectioiitaitli' 49th.'" "This cap'tuires'dfainage , from.the Lev ?nck ro er0. "the .west; The' ewe P. P ties" t_ stern :end is:. undex•zairi with..the. San 'Juan series; a "deep " 3,, sandy soil that can readily accept large volumes af. surface water. The soilsoffsiteto :the. west are much shallower, and as a result contribute asignificantamountofsurface .flow to this. area... However, because the soils.:, are so deep' and, 'coarse, -the stirface': flow- tends to be absorbed acid runsubsurface:. xi titi a] y, ..the ..only.'evidence - of,'drainage.- :is :a 2--4% feet 4ide .ditch (human- made) initiating about -50 -100 feet north of an existing home facing on .Hendricks. The. centerline .pf 'th e drain 'was' flagged (A. on the map) _until i t..tdidens aboutOQ- 350`feet ao:the`• "northe ,: . At that: point.'the_''corridoz bottonu'.became' cite :- q., flat and wide, supporting.anitnderstoyofsloughsedge , and _water parsley -with an overstory- of :cedar, blackcottonwood, ;and willows_ C j2).. ' This" .wetland raas .quite. extensive afeet.wide;'drainin a pprox.'100 . g pgrox. 400 -500 feet to the east where it narrows abruptlydownstreamof - ail old debris jam that appears to -have= dammed 'the drainage; causing the water -to back up. Both 'sides'of this- wetland. were flagged, luosely`:agplying x.989 delineation rules.•'A more detailed delineation shouldbedone 'in, the future as development plans. in:the - area are better defined..• A Local. Improvement District (LID) "road (0) is-apparently proposed'to crosstheeasternhalfof .this'wetiand.. _fit appears: _that, the road will follow a' N/Sline .from the' - eastern property. boundary 'of •the four new houses. adjacent. ,'to49th. , _If ehe wetland is. to' be •crossed, new will. be required to notify theACE; to delineate the wetl'and,.and'to. prepare a mitigation report and plaza:': Downstream of the debris .jam, .the wetland. winds southeasterly in a marrow ' corridor toward the - :back'of...the developed properties .ad-jacent -to 49th :( .#4) The - coriridor °was'.flagged on the.centerli:ne-when- it eras. 4' feet or less wide, but on both .'sides :when, t widened out in'some. areas. :It possible ' °thathistoriaalIy,. the`di rainage flowed. through theJAevelo ed49th;' but at -this , time- :.it .'a g P properties toward ,. ppears ; "that "the'•pr ry channel -flows 'east-','; northeast: along the back and theii'north of: the' cleared,' developed properties. . Some drain a ma _ : tigy.escape subsurface and flow in the ,'southeasterly; direction5), but- .-the primary channel draiiiing -to the northeast intersects withanotherchannelcoming 'in from upslope (JJ6) :. - --A large forested •wetland. complexhasformedattheconfluenceofthetwochannels. A short distance upslopefromthe 'confluen'ce thaththat marks the.beginning of the Clallam soil map unit, indicating t the upslope sous to:.the- north'.and east are :expected to have ashallowsubsurfacetil.L. layer. ' ..The - effect of the till': layer is to, limit soilstorage,- 'xesu],txng :in- excess - surface Viand .soil' water draining downsl ope into ." the; deeper San': 3uazt soil s This ys111, catise: there'..to. be mare : saturated -soilsat,' the toeslgpe: on. this northeastern end .of -the .drainage, -. and..does appear tobe :reflected..:by:.ttifq jncxease:- in.iretlana area. we If ,tile: tuna • p ;i-ywdra page _'Ewhich `drams :northe - dive ast fowaid_ the confluence).•weze: ted" °' fob -9W :,tie sautheasterl`'" clirect£oa bf flbw across ' 1ots,yi 'wosild:_ y'. :the back :of = the,' altrez ,the : hydrology:..of ':the dowristieam `wetlaiid to as unknowndegree,.:': Tii3.s -may xesi t -.ink better:::coiitrol of >stor&tvater, but:. wclearlydefaiiedandmtigatied. fQ otld have to -be r'., 4'. The forested wetland drains from the confluence almost due east toward thebackofthehomesonJackmanStreetbetween50thand51st. Only the southernside. of the wetland complex was- flagged.downstream of-the confluence. -But theupslopeboundarieswereapproximatedontheaerial- photo. A recently - •cleared lot ( ii) behind a home• "facing on.. Jackman appears to be' atleast.-partially' :if -not all in. the - wetland. The vegetation directly .behind theberm-running along the -.western side 6 f -lot is spirea,. -black cottonwood, willoir, .and. - hawthorns all ;hyd rophytic .vegetation indicative of wetland ' status._, :Further more,--t ie..jvegefat on'.pattezns 'indicate. -that water. stands inthis-are- :a for extended : periods - =of .time during -the winter. . There is greatpotential:.for._ future "flooJing. on •the: lot - unless dikes' and •control devices .arewellengineered .and ma%ntai- ned. "`The',_future homeowner should be-notified that ' the back 'of their -property is'in the wetland and should be encouraged tomaintainavegetativebuffer'to•protect downstream water quality. They shouldalsobeencouragedtolocatetheirhomeasclosetotheeasternedgeaspossible. The drainage •turns and tuns to the: south across possibly half. of the .cleared- lot and across the -backs of-several 'other lots along Jackman, Vegetation atthebackof" all these lots is primarily hydrophytic.:.They.appear to have beenbuilteitherin- the wetland or directly beside -the drainage -corridor'.• Thewetlanddrainagethenappearsto .spread across an open grassy area (0) northof49thandcrestofdseveral• 'homes-'fhat ate "located south of 50th. These homesMalmost•- certaizily are located in the middle ' of- the 'original - drainagechannel. Because the San,Juan'soi.ls are so porous and deep, tie majorityustseepdow -ofthewatermnslopesubsurface. 'But small drainage ditches 'around" the homes appear .to -•be designed to- convert surface flow-toward a.ditch:onJackman. '.that flows to" 49th. ....it -is- likely that -at least some of these' houseshavesubsurfacedrains" as well- to .divert seasonal' groundwater from their . foundations.. :. The Agnew soil series. is mapped at the Jackman /49th Street- intersection withthegreatmajority•ag the "Agnew "map unit extending to the "south, under thefairgrounds. The Agnew is a hydric soil•,• and. -it is possible that prior todevelopmentandconstruction•of"the' road, excess drainage from the area' of 49th at least.- meandered through this low -lying area; possibly "subsurface' draining toward what is now Townsend Meadows rather than toward ChineseGardens. The Agnew is fine- textured;-typical of a flood deposit in a quietbackwater, and would not have formed without a source of upslope- sediment. At 49th,.-the drainage flows into - a' 1.2 inch culvert. across ' Jackman' ( #l0) . We ' were: unable' to ,.fii-xd the other -end... of this cuivett, -. but there i' an 'obvious . ditch `runnixig' *long the•m'arth: •side. -of;49th from`the .east -side of. the - Jackman ' intersection ;`...'The ditch widens•-.out.again,-1- lowing northeast.-across. an_opengrassy :area :; (" 11) -, through : an .indised _ ."possibly - ditched drains a cuttin '' - g gbetiveen "two• - homes" - -on, Landis, " ; At 'that. -poi.nt., , the: soils are mapped as .changingfromtheSan- Juan to.'the•' Claliam 46ries.,• rainage: is ctzlvetted•'under'- Landis, drains, east - northeast -across" afieldnorth.:of ahome on 50th,' then through_a culvert under•'Kuhn 'to -a ditch . running directly - X:nto Chinese : -Gardens - " . 5. Since there. is evidence Of. a surface water' connection between all the wetlandsalongthedrainagecorridor, .they would be probably be regulated as a•single wetland - complex- rather than a series of isolated wetlands. .Since. the wetland' is- a.-. relatively. pristine ' fores't.ed complex, it may be.'rated -as a Category 1, making mitigation and `replacement '.ratios very costly.. Impacts should .lie avoided if possible -Aind minim zed. if 'it -is not. possible to- avoid. As described :above far the.LID,.any• impact will : - require an ACE permit at theleast; in additxon.:to mitigati on plans .and wetland delineatidn in 'the area ofimpact. SUMMARY The'riatural 'drainage.corridor'•appeaxs . to meander back and forth. between the50thand51stStreeteasements;.- then. at Jackman drop south to 49th, -GrossJackmanin 'a culvert, then drain northeast again through a narrow but obviousdrainageto -the Chinese 'Gardens- ''The corridor is a series of - jurisdictional wetlands connected by A surface channel. The surface water connection means that they are,not "isolated wetlands" and would be tegulated . as a single jurisdictional- wetland system. When the channel was -less than-4-feet wide,' only the centerline was _ flagged. Both' sides-.6f the corridor 'were .flagged west of the confluence :with theupslopedrainage.'.. *Only. the* south side of the'.corridor was flagged east of 'theconfluence, " :but the upper:side•was approximated` and marked on'the aerial photo. - Arrows on the, serial photo: show the general direction of flowpatterns. The Part Townsend ESA :requ_ ires'. that the. cent_ erline of .the . water co_ urse be surveyed an-d thL- coriidor`-'and'centerlineI'be_ indicated on the Site ConstructionPlan.. The ESA'-does: not clearly. define 'the corridor other" to . -say_ that =it.:._..` is a "natural 'oz-.'parti.ail altered.*watercourse ' or ] ' -lying area that contributes to 'water: quality and stormwater `'and erosion_ ' control .'" These- areas . are._ to ' be identified by 'the Dept.— of Public Works 'from - 'local -knowledge aoutregularflooding "_. -or "potential for - flooding if' existing, drainage is - modified."' :. When -the surveying is completed, the City ESA wetland maps should be updated. The soil mapped for the majority of the . drainage. corridor is the'deep,.porousSanJuan. It appears that characte'risties 'of the-San Juan soil-.have made. this system very forgiving,'.al loving it- -to absorb ekcess .runoff .from upslopeshallowsoils, causing what: ' was surface ;runoff . upslope 'to run subsurface -'alongthe..:bottom slot some': time.: This ekfect gill buffer. the ,puls'e 'of .runoff -- following winter'storms,- thereby- reducing flood potential,• and -will inipzove_::- .:-;.'. water. '-quality. - y. actiiiities = cti-- ectTy' impacts : the wetiaads'.'will.x'e airs ACE- :natifi.cation _ Permittitig, of 'the: actioii The, permit` will' be'=revi ewed'` by :_t he ACE' the -`: r fPA,r. =and various_ State ;Ageiicies`,for::compLiance' with other:wetlinds arid. -water,• quality statutes=: "-'Delineation: and a'a13 Ligation ,report may - tie red: Depending -on `1- he activity;..: .the :City ",may also- require a- "wetlands report anddelineationsiroun. :.the .impacted areas . ;