Ch. 6— Impacts and Mitigation • 127 



actions in the same region. There was generad 

 agreement that without planning, the cumulative 

 impact of activities associated with the regulatory 

 program could indeed lead to serious consequences. 

 Planning required to assess cumulative impacts of 

 individual actions must be done on a large scale — 

 regional, watershed, ecosystem, etc. It was also 

 generally agreed that any analysis of cumulative 

 impacts on an area must of necessity be based on 

 a knowledge of local growth patterns and local plan- 

 ning objectives.' 



Wetland Reviews 



As noted in the Code of Federal Regulations,* 

 "the District Engineer may undertake reviews of 

 particular wetland areas ... to assess the cumu- 

 lative effect of activities in such areas." Some 

 districts have conducted such inventories of wetland 

 resources, called "wetland reviews," particularly 

 where there are large numbers of permit applica- 

 tions and pressures for development. In some cases, 

 the Corps has worked with State and local officials 

 to plan for future demands for development that 

 might require section 404 authorization. Such ac- 

 tivities also can help to reduce the time it takes to 

 make a permit decision and to reduce uncertainty 

 as to which areas are regulated under section 404. 

 These efforts are described below. 



Wedand reviews have been conducted for at least 

 six estuaries on the west coast, one area in Alaska, 

 and in the Atlantic City, N.J., area. Each review 

 is different; however, the review of the Snohomish 

 Estuary by the Seattle District in 1977-78 provides 

 a good example of information that can be pre- 

 sented to help reduce the uncertainty associated 

 with the 404 process. The review's goal was to pro- 

 vide a comprehensive inventory of wedand habitats, 

 a discussion of existing regulatory controls, and 

 recommendations for wetland protection. As part 

 of the project, a complete inventory and mapping 

 of land use and land cover was prepared. In addi- 

 tion, fish and wildlife habitats and physical, cul- 

 tural, and esthetic chau-acteristics were mapped and 

 evaluated. 



From the data gathered, wedand areas within the 

 estuary were designated as areas of importance, 



'U.S. Army Corps of Engineers, 29th Meeting of the Environmental 

 Advisory Board, held Apr. 21-24, 1982, Arlington, Va. 

 '33 CFR 320.4{6)(3). 



areas of environmental concern, and other areas. 

 Areas of importance were those areas with unique 

 resources or those which served critical functions. 

 It was recommended that they be maintained in 

 their present state and that any 404 permit be ap- 

 proved "only if the activity is clearly in the public 

 interest." Areas of environmentad concern were 

 sensitive to development or change, but might have 

 uses that are "consistent with maintenance of their 

 habitat values." It was recommended that "only 

 uses in the public interest and compatible with the 

 habitat values should be approved." Other areas 

 were those in which "new development would have 

 minimal impacts on wetlands and other valuable 

 habitat types." 



Since its completion, the Snohomish Estuary 

 Wedand Study has been used regularly by the Seat- 

 tle District. Within the Regulatory Functions 

 Branch, use of the document has emphasized the 

 identification of wetlands as a means of determin- 

 ing Corps jurisdiction under section 404. As a re- 

 sult, the need for time-consuming site visits has 

 been reduced. It also is used in preapplication con- 

 ferences to inform applicants of issues of concern 

 and to suggest methods for minimizing impacts as- 

 sociated with their proposal. In the Environmen- 

 tal Resources Section, the analysis of wedands val- 

 ues has been used in preparing environmental as- 

 sessments (EA's) of proposed 404 permit activities. 

 The detailed data base presented in the review 

 saved both time and effort in preparing environ- 

 mental documentation. Furthermore, in the winter 

 it provides data that would not be available even 

 on a site visit. On occasion, the review even has 

 been used as a data source for EA's on sites in other 

 estuaries with similar habitats. 



It should be noted that the Snohomish County 

 Planning Department also uses the study to evalu- 

 ate substantial development permits under its 

 Shoreline Master Program. The small county staff 

 lacks the technical expertise to evaluate all the func- 

 tional characteristics and potential impacts associ- 

 ated with a particular site; the review contributes 

 to the accuracy and consistency of their decisions. 

 In addition, the important wedands that were iden- 

 tified in the study have been incorporated as "areas 

 of special concern" in the county comprehensive 

 plan (45). 



