8421 Auburn Blvd., Suite 248 | Citrus Heights, CA 95610 | (916) 822-3230 | madroneeco.com Memo
To:
From:
Date:
Subject:
Rod Stinson/Raney Planning and Management, Inc.
Sarah VonderOhe/Senior Biologist
24 May 2022
570 Crespi Wetland Clarification Letter
Rod:
At your request, Madrone Ecological Consulting, LLC has reviewed the letter dated 8 April 2022 from Wood Biological Consulting and the 11 May 2022 response to our review of the 8 April 2022 letter. At issue is an area that appears to have previously considered a wetland in the biological documentation for the project. Now Wood has further inspected the area and determined that in their opinion, the riser will be placed in an upland. Further clarification should be provided in order to substantiate this determination.
1. There are no U.S. Army Corps of Engineers wetland delineation data forms provided. Much of the information provided in the letter could be used to complete the data forms, but there is still data lacking, percent cover of each plant species, percent of the soil comprised of each soil color in each layer, or any information regarding wetland hydrology for the first two data points. In short, Wood has not provided all of the information required by the U.S. Army Corps of Engineers minimum standards for acceptance of aquatic resource delineations. From the data available to Madrone in the letter, it appears likely that Wood has properly analyzed the data and correctly used it to determine wetland/upland status at the data points.
Update: In the May letter, the delineation forms were provided and appear consistent with the wetland determinations in the April letter.
2. The letter does not state what type of equipment was used to create the line between wetland and upland and locate it on the project map. It could have been digitized on an aerial photograph, bringing into question how accurate an assessment of impacts associated with the riser could be.
Update: the mapping was completed with a compass and tape measure from a known point.
Although unconventional, there is no reason to believe it could not work to use this method.
3. The map provided with the memo could be clearer and we suggest that it only show the original and refined boundary of the wetlands without the land use/impacts overlaid.
Update: there was a project specific reason the map was prepared as it was.
In summary, Madrone’s review was only with respect to the riser area in question and Wood’s use of the data provided in the memo to assess wetland vs. upland status. We did not visit the site or take data of our own to determine the accuracy of the data in the field.