• Separate the list of wetland hydrology indicators into primary and 

 secondary indicators. Primary indicators are more reliable and can 

 be used alone to meet hydrology criterion. Secondary indicators 

 are weaker and can only be used with corroborative information. 



• Remove water stained leaves, trunks, and stems as wetland 

 hydrology indicators; public comments are requested in the 

 Preamble regarding their reliability as indicators of hydrology 

 during the growing season and whether they should be primary or 

 secondary indicators. 



Incorporate localized differences in the growing season; the 

 Preamble solicits comments on the definition of the growing season. 



• Request public comments on three alternatives to identifying and 

 delineating seasonally harder to identify wetland types that are 

 NOT exceptions to the criteria, but may not demonstrate indicators 

 of one or more of the 3 criteria during certain (e.g., dry) times of 

 the year. 



4) Hydric Soils Criterion: 



• Specifically state that hydric soils must be field-verified; hydric soils 

 maps alone are not sufficient evidence of hydric soils. 



Qarify that the three wetland criteria are mandatory except in 

 specified circumstances, and therefore the presence of mapped 

 hydric soils alone cannot be used to delineate an area as a wetland. 



• Incorporate localized differences for certain hydric soil phases. 



5) Wetland Vegetation Criterion: 



Propose the prevalence index approach -- that is, an area meets 

 this criterion if , under normal circumstances, a frequency analysis 

 of all species within the community yields a prevalence index value 

 of less than 3.0 (where OBL = 1.0, FACW = 2.0, FAC = 3.0, 

 FACU = 4.0, and UPL = 5.0). 



• Request public comments on including the Facultative Neutral test 

 as part of the hydrophytic vegetation criterion in addition to the 

 proposed prevalence index approach. Under this proposed 

 approach the criterion would be met if after discounting all 



