U.S. Army Corps of Engineer*
                          WASHINGTON, D.C. 20314-1OOO
         REPLY TO
         ATTENTION OF;
  CECH-OR           •  .                        '-6MAR1992


  SUBJECT:   Clarification and Interpretation of the 1987 Manual
                                          „                 \

-  1.   The purpose of this memorandum is to provide additional
  clarification and guidance concerning the application of the
  Corps  of  Engineers Wetlands Delineation Manual.  Technical Report
  Y-87-1, January 1987," Final Report (1987 Manual).  As discussed
  in my  20  February 1992 memorandum, procedures for the
  identification and .delineation of wetlands must  be fully
  consistent with both the 1987 Manual and the Questions and
  Answers issued 7 October 1991.  The technical and procedural
  guidance  contained in paragraphs 2 thru 6 below  has been prepared
  by the Waterways Experiment Station (WES)  and is provided as
  further guidance.  The following guidance is considered to  be
  .consistent with the  1987 Manual and the 7 October Questions and
  Answers.   Further, this guidance will be presented in the
  upcoming  Regulatory  TV wetlands delineation training sessions in
  FY 92. -  The  alternative technical methods of  data gathering
  discussed below are  acceptable as long as the  basic decision
  rules  (i.e.,  criteria  and indicators)  established in the 1987
 Manual are applied.  Also enclosed is a revised  data form which
 may be used in  lieu "of the routine data sheet  provided with the
  1987 Manual,  if desired.   As  discussed in  my 20  February 1992
 memorandum, to the field,  regional approaches and/or/ alternative
 data sheets must be reviewed  and approved  by HQUSACE (eECW~©R)
,prior to regional implementation.   Notwithstanding this
 requirement, we encourage interagency coordination arid
 cooperation on  implementation "of the  1987 Manual.   Such
 cooperation can facilitate the continued success of our use of
 the 1987 Manual.

 2. Vegetations            .

      a.  Basic rule:  More "than 50 percent of dominant species
 from  all strata are OBL, FACW, or FAC  (excluding FAC-)  on the
 appropriate Fish and Wildlife Service regional list of plant
 species that occur in wetlands.

      b. The 1987 Manual provides that the 3 most dominant      .
 species be selected from each stratum  (select 5 from each stratum
 if only 1-2 strata are present) «.  However, alternative
ecologically based methods for selecting dominant species from   -
each  stratum are also acceptable.  The dominance method described
in the  1989 interagency manual is an appropriate: alternative

  SUBJECT: Clarification and Interpretation of  the 1987 Manual

  method.. (1989 Manual,  p.  9,  para.  3.3)
       c.  The 4 vegetation,strata  (tree,  sapling/shrub, herb, and
  woody vine)  described  in  the 198.7  Manual are  appropriate.
  However, a 5-stratum approach .(tree,  sapling, shrub,  herb, and
  woody vine)  is an acceptable alternative.

       d.  The 1987 Manual  states on page  79 that  hydrophytic
  vegetation is present  if  2 or more dominant species exhibit
.  morphological adaptations or have  known  physiological adaptations
  for-wetlands.  This  rule  should be used  only  after the basic rule
  is  applied;  use caution with adaptations (e.g.,  shallow roots)
  that  can develop for reasons other than  wetness,,  Furthermore,
.  the morphological adaptations must be observed on most    • -
-  individuals  of the dominant  species.

       e.   In  areas where the  available evidence of wetlands
  hydrology or hydric  soil  is  weak (e.g.,  no primary indicators of
  hydrology)t  the Facultative  Neutral (FAC neutral) option
  may be used  to help  clarify  a wetland delineation. . Use of the
  FAC neutral  option is  explained in paragraph 35(a), page 23,
  of the 1987  Manual.  Use  of  the FAC neutral option is at the
  discretion'of the District.  Further, the FAC neutral option
  cannot be used to exclude areas that meet the "basic vegetation
 rule" and the hydrology"and hydric  soil requirements.

 3.  Hydrology:

      a.  Areas which are seasonally inundated and/or saturated  to
 the surface  for a consecutive number of days for more than 12.5
 percent of the growing season are wetlands, provided the soil and
 vegetation parameters are met.  Areas wet between 5 percent and
 12.5 percent of the growing season in most years (see Table 5,
page 36 of the 1987 Manual)  may or may not be wetlands.  Areas
saturated to the surf ace for less than 5 percent of the growing
season are non-wetlands.  Wetland hydrology exists if field
indicators are present as  described herein and In the enclosed
data sheet.

      b.  To evaluate hydrologic data (e.g.,  from stream gages or
groundwater wells) growing season dates  are required.   Soil
temperature regime (i.e.,  period of the year when soil
temperature at 20 inches beJLow the  surface is  above 5  G)  is
the  primary definition  of  growing season, but  data are rarely
available for individual sites.  Broad regions based on soil
•temperature^regime (e.g.,  mesic, thermic) are  not sufficiently
site-specific.  For wetland determinations, growing season can be
estimated from climatological data  given  in most  SCS county sail

 CEGW-OR                         	          .
 SUBJECT: Clarification-and Interpretation of the 1987 Manual

 surveys (usually in Table 2 or 3 "of modern soil surveys) .
 Growing season starting and ending dates will generally be
• determined based on the *!28 degrees F or lower" temperature
 threshold at a frequency of "5 years in 10."  In the south, at
 the discretion of the district, 'it may be more appropriate to use
 the 32 degree F threshold.                   ,  -

      c.  In groundwater-driven systems, which lack surface
 indicators of wetland hydrology, it is acceptable to use local
.Soil Conservation Service (SCS) soil survey information^to
 evaluate the hydrology parameter (p. 37 in the Manual) in
 conjunction with other information, such as the FAC neutral test.
 Use caution in areas -that may have been recently drained.

     •d.  Oxidized rhizospheres surrounding living roots are
 acceptable hydrology indicators on 
 SUBJECT: Clarification and Interpretation of the 1987 Manual

 5.  Methods;;
                     0                                            r
      a.  As stated 'in the 1987 Manual (footnote, p. 76),
 alternative plot sizes arid dominance measures are acceptable.

      b.  For comprehensive determinations involving a patchy or
 diverse herb layer,  a single, centrally located 3.28 x 3.28-
 foot quadrat may not give a representative sample.  As an
 alternative, the, multiple-quadrat procedure presented in the
.1989 Manual (p. 42)  is recommended.      ;

 6.  Problem Areas

      a.  Page 93, paragraph 78 of the 1987 Manual states that
 similar problem situations may occur in other wetland types;
 therefore,  problem areas are not limited to this list.
                                        .    •          =«•
      b.  Problem soil situations mentioned elsewhere in the
 Manual include soils derived from red parent materials,  some
 Entisols, .Mollisols, and Spodosols.                  .

 7.   Questions concerning this information should be directed to
 Ms.  Karen A.  Kochenbach,  HQUSACE (CECW-OR) ,  at (202)  272-1784,  or
 Mr.  James S.  Wakeley,, WES,  at (601) 634-3702.
End                    , ^vARTmm E.  WILLIAMS
                             Major General, USA   .
                             Directorate of Civil Worles
(SEE PAGE 2 & 3)

                                             DATA FORM
                                ROUTINE WETLAND DETERMINATION
                               (1987 COE Wetlands Delineation Manual!
Project/Site: '
Investigator: >
Do Normal Circumstances exist on the she?
Is the site significantly disturbed (Atypical Situation}?
Is the area a potential Problem Area?
(If needed, explain on reverse.)


Community ID:
Transect ID:
Plot ID:

Dominant PSant Soaetea • Stratum Indicator
1. ' ' '
2. " '
4. •>'•••" '
5. '
fi. . • -
1. • ' •
Percent of Dominant Species that are OBL. FACW or FAC
Remarks: * .
Dominant Want Soeetes Stratum Indicator

13- ' .._••••
is. - - . ..

     Recorded Data (Describe in Remarks)?
          _ Stream. Lake. , or Tide 6miQ«
           •  Aerial Photograph*
          __ Other             '
     No Recorded Data Available
  'Field Observations:

    Depth of Surface Water:

    Depth to Free Water in PsC
Wetland Hydrdoev indicator*:
   Primary Indicators:
           Inundated                   .
        	; Saturated in Upper 12 Inches
           Wat«f Marks
        	, Drift Lines        .    -
         '  Sediment Deposits
        '   Drainage Patterns in Wetlands
   Secondary Indicators (2 or more required):
        	f Oaddfced Root Channels in Upper 12 Inches
           Watar-Stainsd Laavsa
           Local So3 Survey Data
                                                                 Other (Explain in Remarks)

    Mop Unit Name
    (Series «nd Pliaie):
    Taxonomy (Subgrouol:
                                              Drainago Class:	   _
                                              fidd Observations
                                               Confirm Maoped TYP«?  Yes  No
    Profile Description;
    finehM)    Horizon
Matrix Color       Mottle Colors       MottU              Taxturo. Concretions.
(Munsell Moist)     (Munsell Moistl    . * Abundance/Contrast   Struerufg. etc.	
   Hydric So3 IrxCc*tor»:
            „ „ Hi«to«ol
           ___>Ki»tic Eptpodon
              ^ulfidi'e Odor
           ___ Aqiao Mot«ura
           - - Reducing Condition*
              Glrved or Low-Chroma Color*
                              __ Concretion*
                              .High Organic Content in Surface Layer in Sandy Soils
                              . Organic Streaking in Sandy. Soils
                              . Listed on Local Hydric SoQs Ust
                              _ lasted on National Hydric Soils List
                              . Other (Explain in Remarks)
  Hydrophyric V*g»t«ion Present?
  Wetiand Hydrology Prmsant?
  Hydrie Soils Pr»«ent?
           Ymm   No  (Orel*)
           Yes   No
           Y»s   No
                                                        Is tWs Sampfing Point Within s W«tiand?    Y«  Ne
                                                                          Approvec oy HQUSACE a/32.

                       DEPARTMENT OF THE ARMY
                          U.S. Army Corpi of Engineers
                         WASHINGTON. O.C. 20314-1000
         REPLY TO   •
         ATTENTION OF:                         7 October 1991
                      e                    •               - ' .


 SUBJECT:  Questions  & Answers on  1987 Manual                •

 1,  In response to questions froai the fieldr the  Qs  &'AS  on  the
 1987 Corps of Engineers Wetland Delineation Manual  (1987  Manual)
 have been further clarified (in particular,  questions  #7  & 8).
 We clarified that for saturated only  systems, the saturation must
 be to the surface for the appropriate number of days during  the
 growing season.   Furthermore, we"?clarified that the  number of
 days, for inundation or saturation to  the surf ace  are consecutive,
 not cumulative.   The' enclosed Qs  and  As -dated 7 October,  1991
 supercede those previously distributed under the  coveo* memorandum
 of 16 September, 1991.

 2. .1 want to again emphasize, that the 1987 Manual stresses the
 need to verify that all three parameters  exist prior to
 identifying and  delineating an area as a  wetland.  Further., the
 1987 Manual focuses on hydrology  (i.e., inundation &\or
 saturation to the surf aicej,'  In situations where hydrology is
 questionable,  the 1987 Manual requires stronger evidence
 regarding the hydrophytic nature of the vegetation.  The 1987 "
 Manual also stresses the need to use sound professional
 judgement,  providing latitude to demonstrate whether an area is a
 wetland or not based on a holistic and careful consideration of
 evidence for  all three parameters.  As indicated in the 1987
 Manual and the attached Qs and As, careful professional judgement
 onust be used  in situations where indicators of hydrology are not
 clear and the  dominant vegetation ,is facultative.
                               F,  STUDT . --....'  ...
                         Chief, Regulatory Branch
                         Operations,  Construction and
                               Readiness Division
                         Directorate  of Civil Works

                          Questions s Answers
                   on 1987 Corps of Engineers Manual '

  l.Q.  What is the definition and practical interpretation of the
  growing season which should be used in the application of the 1987

    A.  The 1987 Manual defines the growing season as "the portion of
  the year when soil temperatures at 19.7 inches below the soil
  surface are higher than biological zero (5 degrees C)M.  This is
  the definition found in Soil Taxonomy, and growing season months
  can be assumed based on temperature regimes .(e.g., mesic:  March-
" October) .  The 1987 Manual further states this period can be
  approximated by the number of frost-free days.  The Waterways
  Experiment Station (WES) indicates that the county soil surveys,
  which utilize 32 degrees,  provide the growing season for each
  county.  There is some flexibility in the determination of the  .
  growing season in the 1987 Manual.   The growing season, based on
  air temperature in the county soil surveys,  can be approximated as
  the period of time between the average date of the "first killing
  frost to average date of the last killing frost,  which sometimes
  does not accurately reflect the period of time when the soil
  temperatures are higher than biological zero.   The source  of the
  information may vary,  however,  the. growing season generally is to
  be determined by the number of killing frost-free days.  In certain
  parts of  the country where plant communities in general have become
  more adapted to regional- conditions,  local means of determining
  growing season may be more appropriate and can be used.

  2.Q.   Should the determination of hydric soils be based on the
  presence  of an indicator listed in the 1987  Manual or on the series
  name appearing on the  Hvdric Soils of  the United States list,  an
  indicator which is  listed as less reliable in  the hierarchy of
  bydric soil indicators in the 1987 Manual?

   A.  -The order of  soil indicators reliability as listed in the
  1987 Manual remains valid  and will be  used.  The  reliability of the
 'indicators  is based on the  fact-that field verification of a soil's
 hydric characteristics'" is more  accurate than mapping  or  soils
  lists.  Soils listed on the most  recent Hydric Soils  list have been
.  determined  by the National  Technical Committee far Hydric.Soils .  .
  (NTCHS) to  meet the criteria  for  hydric soils.  When  in the field,
 verification  that mapped--hydric soils  actually exhibit indicators
 identified  in the 1987 Manual for hydric soils  is recommended.
 Although a  soil may appear  on the list of hydric  soils, inclusions
 or disturbances may alter this designation to  some degree, so  the
 list alone may not  always be reliable*   In obvious wetlands, if the
 soil is on the list and the area meets the hydrology and vegetation
 criteria, the area  is a wetland.  As found with the 1989 Manual,
 one cannot rely solely on the fact that  a soil  is mapped as hydric
 in making the wetland delineation.  In all cases„ best professional
 CECW-OR, .October 7, 1991                                    Page 1

  judgement should be used.  The  county lists provide  valuable
  information,  but again should not solely be relied on to make a
  final determination as to whether hydric soils  are present.
  Verification of the presence of at least one of the  indicators for
  hydric soils on the list  (pgs.  30-34)  is required in conjunction
  with the use of a county soils  list.   The national soils list to be
  used has recently been updated  by the NTCHS (June 1991),  and this
  list vill be  used by the Corps  in conjunction with the 1987 Manual.

  3"Q:  .H?w should the 1987 Manual be applied with respect to the
  definition of "normal circumstances"?

  .A.   The definition of "under normal  circumstances"  in the 1987
  Manual states briefly that "this term  refers to situations in which
  the vegetation has not been substantially altered by aan«s
  activities".   As stated in item #3 of  the memorandum of 27 August,
  1991,  the definition of normal circumstances used in the  1987
  Manual, has been clarified by Regulatory Guidance Letter  (RGL)  90-7.
 Although  this RGL deals primarily with agricultural activities in
 wetlands,  paragraphs #3 & #4 discuss normal  circumstances with
 respect to all areas potentially subject to  404.  Further guidance
  on normal circumstances is found in RGL 86-9 regarding construction
 sites  and irrigated wetlands.   The followed in
 preferential  sequence of;  1)  RGL 90-7, 2) RGL 86-9,  and 3) 1987
 Manual.              •                        .

 4.Q.   Does the vegetation  criteria in the i987 manual require  the
 use of the facultative (FAC)-neutral vegetation test (i.e.,-count
 the dominant species wetter & drier than FAC, and ignore all of the
 FACs in the vegetation determination) ?                       • '

  •A.   While the 1987 Manual mentions  use of. the FAC-neutral test
 for determining the presence of  wetland vegetation in several
 places, the first indicator of wetland vegetation criteria is the
 presence of more .than 50% of the dominant plant/species FAC or
 wetter (not including FAC-  species, which are considered non-
 wetland indicators under the 1987 .manual).  The  indicator status of
 each  of the dominant species is  determined by consulting the
 current regional plant list published  by the FWS.  The 1987 Manual
 provides an option in this determination of  applying  the FAC-
 neutral test in cases where the  delineator questions  the status
 designation of a particular plant species on a subregional basis
 (see page 23).  As always, any deviation from established protocol
 requires documentation.  The FAC-neutral option may also prove
 useful in questionable areas or when the determination relies on
 the vegetation call in an area that is  not otherwise an obvious
 wetland.   Specifically, the 1987 Manual is; replete wita cautions
 and guidance that the Corps regulators  roust  be confident that the
 area is ^ wetland when the area has1 a FAC-dominated plant community.
Uncertainty regarding the status of an  area as a wetland where the
 dominant vegetation is FAC would be a valid reason to use  the FAC-
neutral option.   Situations exist where use of the FAC-neutral
CECW-OR, October 7, 1991             -            .            Page 2

 method will not serve to provide any additional information as to
 the hydrophytic nature of the plant community (e.g.," all species
 are FAC or there is an equal number of species wetter and drier  .
 than FAC such that they cancel each other out). = In these cases, it
 may be appropriate to consider the + and - modifiers associated
 with some FAC specie's, which indicate the species frequency of
 occurrence in a wetter or drier environment,  in the Coverall
 assessment of the vegetation parameter.  Documentation supporting
 reasons for using the FAC-neutral option must always be provided
 and acceptance of delineations, as always, remains up to the
 discretion of the District.

-5.Q.  Can indicators for any of the criteria  in the 1989 Manual be
 used as indicators for verification of the same or other criteria
 presented in the 1987 Manual?                                .

   A.,  The indicators of hydrology in the 1987 Manual differ from-
 those of the 1989 Manual, and are not interchangeable.   In
 particular,  the hydrology determination in the 1989 Manual often
 relied on evidence of properties from the soil and/or*vegetation
 parameters.   Indicators provided in the 1989  Manual for field
 verification of a certain criterion that are  not presented in the
 1987 Manual  for application with the same criterion cannot be used
 except as additional information in support of the verification.
 It is -unlikely that an area which is a wetland will fail to meet a
 criteria utilizing the indicators which are listed in the 1987

 6.Q.   Will the other Federal agencies be utilizing the  1987 Manual
 in their wetland determinations as well as the Corps of Engineers?

   A.   EPA has concurred with the Corps using  the 1987 Manual for
 all actions.   Further, we understand that EPA will likely use the
 1987  Manual  for EPA's delineations as well«   The other  agencies
 (SCS  & FWS)  typically do not make delineatipns for purposes of
 Section  404.                     «

 7.Q.   To what depth should one look in the soil to find indicators
 of hydrology?

   A.   In accordance with the 1987 Manual's guidance.on  reading soil
 color *(D2),  after digging a 16" soil pit observations should be
made  immediately below the A-horizon or within iow of-the soil
 surface  (whichever is shallower).   This guidance pertains to
 observations  of indicators of the soil criterion..   For  indicators
 of saturation to the surface in the hydrology criterion,.
 observations  are made within a ma j or portion  of the root zone    "
 (usually within 12") ,  again in the 16" pit.  Visual observation of
standing water within 12M of the surface may#  under certain • .
circumstances,  be considered a positive indicator  of wetland
hydrology (i.e.,  saturation to the surface) as stated on page 38«,
CECW-OR, October 7, 1991                                     Page 3

  When using water table within 12" of the  surface  as  an  indicator of
  hydrology,  care must be used to consider  conditions  and the soil
  types (i.e.,  to ensure that the capillary ability of the  soil
  texture  is  considered, in regard to the water table depth) .
  Vegetation  and  soil properties used in the determination  of
  hydrology  in  the 1989 Manual,  are typically not available for field
  verification  of this criterion in the 1987 Manual.   However, the   •
  1987 Manual allows  for some flexibility with regards to indicators
  of wetland  hydrology, and states that indicators  are not  limited to
  those listed  on pages 37-41.   Other indicators, such as some type
  of recorded data (e.g.,  soil surveys which provide specific and
  strong "information  about the soil series'  hydrology) may be used to
.  verify a wetland hydrology  call in a saturated but not  inundated
  area.  Appropriate  documentation to support the call is necessary
  in all cases.

  8.Q<  "What  length of  time must wetland hydrology be present for an
  area to be determined a wetland under the  1987 Manual? .
          '  '   •   '     -            .  . •  •               £
  ^A. . In the hydrology section of Part III, the 1987 Manual
 discusses the hydrologic zones which were developed through
 research at WES to indicate the  duration of inundation and/or soil
 saturation during the growing  season. Wetland hydrology is defined
 in the 1987 Manual as the sum total of wetness characteristics in
 areas that are inundated or have  saturated soils for a sufficient
 duration to support hydrophytic vegetation. The 1987 Manual
 discusses hydrology in terms of a percent of the growing season
 when an area is wet (page 36) .  Generally speaking^  areas which are
 seasonally inundated and/or saturated to the surf ace for more "than
 12.5% of the growing season are .wetlands.   Areas saturated to the
 surface between 5% and 12.5% of the growing season are sometimes
 wetlands and sometimes, uplands.  Areas saturated to  the  surface for
 less than 5% of the growing season are non-wetlands.   The percent
 of growing season translates to a number of days,  depending on the
 length of the growing season in any particular  area  (e.g., 12.5% of
 a 170 day growing season is  21 consecutive days).  This  system for
 the  classification of hydrologic zones based on stream gauge data
 transformed to mean sea level elevations is useful as a  guide to
 time^frames  of wetness sufficient to create wetlands.  The length
 Of time an  area  is wet for hydrology is based on consecutive days
 during the growing season". "If an area is only saturated  to the
surface for  a  period of between 5% and 12.5% of the growing season
and no clear indicators of wetland hydrology exist (i.ea,  recorded
or field data; also  see answer #7 above),  then  the vegetation test
should be critically reviewed.   Specifically, in such cases a
vegetative community dominated by FAC species would generally     •  -
indicate that the area is not a wetland (unless the FAC-neutral
test was^indicative  of wetlands).  The actual number  of  days an
area is inundated and/or saturated to the  surface  for an area to be
called a wetland varies;  the identification of  an  indicator of
recorded or  field data is necessary to document that  an  area meets -
CECW-OR, October 7, 1991                                     Page  4

   the wetland hydrology criterion of the 1987 Manual (i.e., the list
   of hydrology  indicators on pages 37-41, which are to'be used in the
   preferential  order shown; also see question #7).  The number of
   days specified in the June 1991 Hydric Soils of the United Sta-h^c'
   (i.e., usually more than 2 weeks during the growing season) as the
   criteria for  hydric .soils pertains to hydric Soils and not the
   hydrology criterion of the 1987 Manual, which varies with the
   growing season as previously discussed.

   9.Q.  Will delineations made now under the 1987 Corps Manual be
   subject to redelineation under the revised 1989 Manual after it is

    A.  Wetland determinations made after 17 August, 1991, are made
   following the guidance provided in the 1987 Corps Manual and '
   memoranda of  23 & 27 August, 1991 and these questions and answers.
   These delineations are subject to and remain valid for the period
   of time described in RGL 90-6.  As discussed in Issue #4 of the
   preamble to the proposed revisions to the 1989 Federal Manual for
   Identifying and Delineating Jurisdictional Wetlands issued 14
  August in the Federal Register, wetland calls made after the
   issuance date of these revisions but prior to f inalization of the
  revised manual may be subject to redelineation under the new manual
  at the request of the landowner.  Final actions will generally not
 • be reopened.  Wetland calls made under the 1989 Manual are already
  subject to redelineation under the 1987 Manual in accordance with
  the guidance issued 23 August.  Until such time as the proposed
  revisions to the 1989 Manual are finalized, it is unclear as to
  what effect, if any,  the equity provision in the preamble to the
  proposed revisions will have on the 404 program.  . Therefore,' *
  written delineations made with the 1987 Manual will explicitly
  state they are final for a period of three years as specified in
  HGL 90—6,  subject to any equity provisions that may be adopted as
  part of implementation of the final 'revisions to the 1989 Manual.

  10.Q.  How.does the 1987 Manual compare to the 1989 Manual or its
  proposed revisions?

     A.  The  various manuals have been compared by WES and the side—
  by-side comparison is available. for your information.
%            ,         '                                     *
I  11.Q. Will applicants be subject to delay with use of  1987 .Manual?  .

     A. During the  initial transition to use of the 1987 Manual for
- wetland delineations  as of 17 August,  some delays are  unavoidable. .
  The Corps  field offices must adhere to the procedures  provided  in
  the 23  August  memorandum,  while striving to expedite the review
 process to  the extent possible.   No offices should indicate "that
 they cannot operate due to lack of guidance during this transition .
 period. HQUSACE recognizes that there will be delays associated
 with implementing the Corps 1987 "Manual and we will take these
 delays  into account when reviewing district application performance
 CECW-OR, October 7,  1991                                     Page 5

 data'(e^g., % of IPs evaluated in 60 -days). .  Districts should not
 stop the permit clock,  but should indicate where substantial
 impacts to permit evaluation performance have resulted from
 implementation the 1987 Manual»     •
CECW-OR, October 7,  1991 -     ,      .                        Page  6