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Georgia Department of Community Affairs
Jim Higdon, Commissioner
Office of Coordinated Planning
1200 Equitable Building
100 Peachtree Street
Atlanta, Georgia 30303
An Equal Opportunity Employer
library
US EPA Region 4
61 Forsyth St° S W
Atlanta, GA 30303-3104
THE PUBLICATION OF THIS DOCUMENT WAS FINANCED IN PART THROUGH A WETLANDS
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Objectives of this Guidebook
Through its administration of the planning process mandated by the Georgia Planning Act
of 1989, the Department of Community Affairs (DCA) encourages wise land use at the state, regional, and
local levels. Wise land use entails using the state's natural resources in a judicious manner, thereby
guarding the health and welfare of the public as well as ensuring the long-term economic health of
Georgia's communities.
It has been recognized that certain natural resources, including wetlands and water supply
watersheds, have been threatened by unwise land use practices. These practices have included
destroying wetlands by filling them and converting them to other land uses and other activities that have
led to degradation of water quality within water supply watersheds.
An array of state and federal laws has been designed to protect wetlands and watersheds. Lack of
understanding of these laws has led to a certain amount of confusion and frustration among landowners,
frequently as a result of inadvertent violations or long delays in acquiring needed permits. This is
particularly true in the case of wetlands, where the problems are increased by general confusion over
what constitutes a wetland.
Under these confused circumstances, the safe-guarding of natural resource protection and
economic well-being may seem difficult to reconcile. Promotion of wise land use policy and compatible
natural resource protection and economic growth are the primary reasons DCA has compiled this
document. Reconciliation is attempted by clearly explaining federal and state laws and policies with
respect to wetlands and watersheds, the types of permits necessary for development, the application
processes for these permits, and ways of facilitating the permitting processes. A discussion of site design
options that may help the landowner or developer design a project that avoids or minimizes impacts on
wetlands and watersheds is also included.
It should be noted that the opinions and conclusions expressed in this document are those of DCA
and do not necessarily reflect those of the Georgia Department of Natural Resources or the U.S.
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lL$iim(il(DwiEi
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Introduction
This guidebook is designed to aid property own-
ers and developers in understanding the rationale
and legal framework of wetland and watershed pro-
tection, the Clean Water Act (CWA), Section 404
permitting process with respect to wetlands and de-
velopment techniques for minimizing damage to
these ecologically important environments. The
protection of coastal marshlands by the Georgia De-
partment of Natural Resources (DNR), mandated
by the Coastal Marshlands Protection Act of 1970,
as amended, is also discussed. The ongoing contro-
versy surrounding wetland definition is not dis-
cussed, and the problems of wetland delineation are
only briefly discussed. Instead, this guidebook is
intended as a general guide to techniques of con-
struction and site design that the landowner or de-
veloper can use to minimize damage to wetlands
and watersheds. In addition, guidance with respect
to the Section 404 permitting process is intended to
facilitate understanding and reduce the chances of
unwelcome delays for individuals making a 404 per-
mit application. The Section 404 permitting pro-
cess is fully explained in Appendix A.
What is a Wetland?
A wetland, as the name suggests, is characterized
by the presence of water, either at the surface or
just beneath it. Some wetlands, such as marshes,
swamps and bogs, are easy to recognize because
they are periodically or permanently covered with
water. Other wetlands are more difficult to recog-
nize because they are only infrequently flooded and
their soils only saturated for a relatively brief peri-
od during the year. Estimates of the total wetland
Georgia Department of Community Affairs
Landowners' Guide to Wetlands and Watersheds
acreage in Georgia have varied, depending on the
definitional criteria used and research technique
employed. It has been estimated that Georgia pos-
GENERALIZED LOCATION
OF GEORGIA'S WETLANDS
1^*1 Riverine Wetlands
associated with streams
throughout Georgia
E3 Carolina Bays or
Limesinks Common
EE3 Cypress & Gum Ponds
Common south of this
line
Coastal Marshlands
Common
Okefenokee System
Figure 1
sessed as many as 6.8 million acres of wetlands in
1790. The U.S. Fish and Wildlife Service Sur-
vey of 1956 estimated almost 6 million acres of
wetlands in the state. A more recent analysis by
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Landowners' Guide to Wetlands and Watersheds
DNR, using satellite imagery, estimated total
acreage at 4.3 million. However, the DNR analysis
was hampered by difficulty in distinguishing be-
tween some wetlands and land uses that looked
similar in satellite imagery. Recent estimates by
the Fish and Wildlife Service have placed total
acreage at approximately 5 million. These wet-
lands, in their various forms, are found in all re-
gions of the state, although they are most heavily
concentrated in the coastal plain (see Figure 1).
Throughout much of our history, wetlands were
regarded as wastelands and centers of disease, to
be drained or filled and converted to their "highest
and best use" as quickly as possible. It was not un-
til the 1950s that the ecological values of wetlands
began to be generally recognized. These values in-
clude processing and cleansing surface water sup-
plies and serving as retention areas for stormwater
runoff. Coastal wetlands (saltwater marshes) have
been recognized as irreplaceable breeding grounds
and nurseries for commercially important seafood
resources. As such, they are protected by the
state's Coastal Marshlands Protection Act. Wet-
lands are also valued as habitats for endangered
and threatened plant and animal species and as
recreational resources.
In recognition of the value of wetlands, certain
activities within wetlands are regulated by the fed-
eral and state governments, as well as many local
governments. Actions that have an adverse impact
on the ecological functions of wetlands are general-
ly regulated at the federal and state levels. Activi-
ties that result in the discharge of sediment into a
wetland or filling of a wetland are regulated
through a permitting process administered by the
Page 2
U.S. Army Corps of Engineers, while oversight of
wetland protection and guidance are provided by
the Environmental Protection Agency (EPA). In ad-
dition, the State of Georgia, in cooperation with the
Corps of Engineers, protects coastal marshlands by
requiring a joint permit for wetland altering activi-
ties.
FLOOD CONTROL
Wetlands associated
with floodplains serve
as retention areas for
stormwater runoff.
In Figure 2a, a
development has
been placed adjacent
to wetlands. Figure 26
shows the same area
with development
extended over filled
wetlands. The rela-
tive flood levels for
the two developments are
shown in Figures 2c &
2d. In 2d, areas that
formerly acted as
retention depressions
have been filled and
impervious surface
greatly increased. As
a result, runoff has
increased and flood
levels are higher L
than they would have »-
been otherwise.
Pliltllll
Figure 2
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Why Should Wetlands Be Protected?
Although they are often seen by the uninformed
as nuisances, wetlands perform a variety of impor-
tant environmental functions. It has been estimat-
ed that wetlands allow an annual saving of billions
of dollars that would otherwise be spent on waste
FILTRATION OF
POLLUTANTS & SEDIMENT
Wetland plants aid water quality by trapping
and retaining sediment, nutrients
(nitrogen & phosphorus),
and toxicants (pesticides, heavy metals, etc.).
Figure 3
Georgia Department of Community Affairs
Landowners' Guide to Wetlands and Watersheds
water treatment, flood protection and repair of dam-
age from floods (see Figure 2). As topographically
low areas, wetlands form natural retention and de-
tention ponds that intercept and hold stormwater
runoff. Wetlands also act as buffers between open
water and dry land, guarding against erosion by
wind and waves.
Many threatened and endangered species,
such as these woodstorks, are dependent
on wetlands for habitat.
Figure 4
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Landowners' Guide to Wetlands and Watersheds
SEAFOOD RESOURCES
RedSbapper
(Lutjanus campechanus)
King Mackerel
(Scomberomorus cavalla)
Jack
(Several Genera)
Ale wife
(Alosa pseudoharengus)
Striped Mullet
(Mugil cephalus)
Porgy
(Several Genera)
Spotted Seatrout
(Cynoscion nebulosus)
Flounder
(Seueral Genera)
Many commercially important fish species,
including those shown here, depend on
coastal marshlands during a portion
of their life cycles.
Figure 5
Page 4
Wetland plants serve as an effective natural wa-
ter filter system, trapping pollutants and sediment
in their root systems (see Figure 3). Many of these
plants have features that allow them to remove ex-
cess nutrients, such as nitrogen and phosphorus,
from surface waters. If not kept in balance, nutri-
ents lead to the overgrowth of algae. Water bodies
affected in this way become "oxygen poor," so that
fish and other species cannot exist within them.
Surface water recharge is another vital function
of wetlands. During wet seasons, wetlands store
large amounts of water which is gradually released
into streams, rivers and ponds during the spring
months, when water levels are declining.
A wide variety of animals and plants live exclu-
sively within wetlands, including a large number of
endangered and threatened species (see Figure 4).
It has been estimated that wetlands sustain nearly
one-third of the nation's threatened or endangered
species. In addition, many species, such as ducks
and geese, rely on wetland habitats during their an-
nual migrations. Coastal marshlands, as well as
many fresh-water wetlands, serve as breeding
grounds and nurseries for commercially and recrea-
tionally important fish and shellfish resources. Ap-
proximately 60-80 percent of major U.S. commercial
fishes depend on estuaries and saltwater marshes
for spawning grounds or nurseries. These include
bluefish, menhaden, sea trout, flounder, fluke, mul-
let, striped bass and drum (see Figure 5).
Half of the fish species caught by recreational
fishermen, including catfish, trout and largemouth
bass, rely on wetlands in one way or another. Many
wetlands serve as recreational resources for
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RECREATION
Many wetlands are valued as recreational
resources. In addition, many fish valued by
sports fishermen rely on wetlands as
breeding grounds and nurseries.
Figure 6
fishermen, boaters, campers and hikers (see
Figure 6).
Finally, Georgia's wetlands are valued for their
timber resources. It has been estimated that the
timber in southern wetland forests is worth over 3
Georgia Department of Community Affairs
Landowners' Guide to Wetlands and Watersheds
billion. If managed wisely, these forests will contin-
ue to be an important source of timber.
Identification of Wetlands
Introduction
In order to preserve the vital ecological functions
of wetlands, development in and around wetland ar-
eas should be avoided where possible, or performed
in ways that minimize detrimental impacts to wet-
lands. Minimizing impacts is also a necessary com-
ponent of development in complying with federal,
state and in many cases, local government regula-
tions. Such compliance begins with the identifica-
tion and delineation of wetlands on a property that
someone wishes to develop.
Wetland Types
Wetlands vary greatly in terms of size, physical
form, function and predominant vegetation. For a
comprehensive discussion of wetland types, see
Cowardin, et al., Classification of Wetlands and
Deepwater Habitats of the United States (1979). For
purposes of this discussion, wetlands can be divid-
ed into two broad categories, tidal wetlands and
nontidal wetlands. Tidal wetlands, commonly
called coastal marshlands, are located in the low-
lying areas along Georgia's coast and are subject to
regular or periodic inundation by oceanic tides.
There are over 500,000 acres of coastal marshes in
the state's six coastal counties. Generally, these
marshlands are characterized by the presence of
grassy plants such as saltmarsh cordgrass (Sparti-
na alterniflora) and needlerush (Juncus roemeria-
nus) (see Figure 7). The Georgia Coastal Marsh-
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Landowners' Guide to Wetlands and Watersheds
TYPICAL COASTAL
MARSHLAND PLANTS
Smooth Cord Grass
(Spartina alterniflora)
Saw Grass
(Cladium jamaicense)
Salt Reed Grass
(Spartina cynosuroides)
Black Needlerush
(Juncus roemerianus)
Sea Lavender
(Limonium spp.)
Salt Meadow Grass
(Spartina patens)
Figure 7
Page 6
lands Protection Act of 1970 defines coastal marsh-
lands as wetlands that extend to an elevation of 5.6
feet above the mean high tide level. Activities that
alter a coastal marshland require a permit issued
by the Coastal Resources Division of the Georgia
Department of Natural Resources.
Nontidal wetlands occur throughout the state..
These wetlands are often more difficult to identify
than coastal marshlands, primarily because of the
wide variety of forms they can take. A general
knowledge of wetland types and reference to wet-
land maps available from the federal and state gov-
ernments, sometimes supplemented by local maps,
can ease the difficulty of locating wetlands on a par-
ticular parcel.
Common types of nontidal wetlands include:
(1) riverine wetlands, commonly called bottomlands;
(2) Carolina bays; (3) cypress and gum ponds; and
(4) limesinks. Riverine wetlands are found in the
floodplains of streams and rivers. These wetlands
are periodically covered by floodwaters and are im-
portant because of the roles they play in flood con-
trol and water quality. Riverine wetlands, quite
variable in composition, are found in all parts of the
state. They are often forested, with bald cypress
{Taxodium, distichum) and water tupelo (Nyssa
aquatica) frequently associated with so-called
brown-water streams in the coastal plain, while
pond cypress (Taxodium ascendens) and swamp
blackgum (Nyssa biflora) are frequently associated
with black-water streams (see Figure 8). Many oth-
er broadleaf trees are also present in riverine wet-
lands, including yellow poplar, sycamore, several
species of oak, red maple, sweetgum, green ash, wa-
ter hickory, ash, cottonwood and river birch. Van-
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ous needle-leaf trees are also common, including
loblolly pine, spruce pine and pond pine. Cypress
and gum ponds are characterized by their vegeta-
Landowners' Guide to Wetlands and Watersheds
tion, which includes pond cypress and swamp black-
gum. These wetlands are most common in the
coastal region of the state.
TYPICAL FRESHWATER WETLAND TREES
Figure 8
Georgia Department of Community Affairs
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Landowners' Guide to Wetlands and Watersheds
Carolina bays are primarily found in the south-
central to southeastern area of Georgia. They are
characteristically oval in shape and vary widely in
size and water depth. There is a general northeast-
to-southwest trend to Carolina bays, and to the
south and east they have raised sandy rims. The
origin of Carolina bays is something of a mystery.
Common plants associated with these wetlands
include fetterbush (Lyonia sp.), green briar (Smilax
sp.), switch cane (Panicum sp.) and buttonbush (Ce-
phalacanthus sp.). Common trees include pond
pine (Pinus serotina) and several species of bay
(.Magnolia, Gordonia and Persea). Limesinks are
depressions formed when underground caverns, oc-
curring in limestone bedrock, collapse. Most lime-
sinks are found in the southwestern portion
of the state, where limestone is common. Some
limesinks also occur along the fall line in central
Georgia and in the northwest corner of the state.
It is difficult to generalize about characteristic vege-
tation. A wide variety of plants are associated with
limesinks.
How to Determine if there are Wetlands on
Your Property
A Section 404 permit is required for most activi-
ties involving dredge and fill in wetlands. The de-
lineation of such wetlands on a site must be made
directly by the U.S. Army Corps of Engineers or by
an approved consultant whose work is subject to re-
view by the Corps. However, a landowner who sus-
pects that there are wetlands on a site can call
upon a number of informational resources and tech-
niques to determine, in a general and preliminary
fashion, if wetlands are present.
Page 8
Step 1. Wetland Maps. Wetland maps are valua-
ble general references and should be consulted as a
first step in determining the presence of wetlands.
National Wetlands Inventory (NWI) maps are avail-
able from the U.S. Geological Survey and the Geor-
gia Geologic Survey Sales Office. It should be kept
in mind that the scale of these maps limits their
usefulness in delineating wetlands within particu-
lar property parcels. They are drawn at the same
scale as U.S.G.S. topographic quad maps, with a
scale of 1 inch on the map representing 24,000 inch-
es on the ground (approximately two-fifths of a
mile). County soil surveys can also be useful, indi-
cating the locations of poorly drained soils. Hydric
soils include soils that are formed by ponding or sat-
uration for as little as seven consecutive days dur-
ing the growing season (which lasts from February
to October for much of Georgia). Local governments
often maintain an archive of these and other maps,
such as floodplain maps, and can supply copies to
the public. However, soil surveys are not available
for all locations. Every county in Georgia has a hy-
dric soils list that is maintained by the Soil Conser-
vation Service field office. Wetland landcover maps,
at a scale of 1:24,000, have also been compiled by
DNR and are available for inspection at most of the
state's regional development centers.
Step 2. General Inspection of the Site. Walking
over the site is a useful first step in searching for in-
dications that wetlands may be present. One
should look for indications of the presence of water
at or just beneath the surface, such as mud on the
trunks of trees, mud covered leaves on shrubs, or
fences containing obvious water-deposited debris.
If the soil is saturated for two weeks or more dur-
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Landowners' Guide to Wetlands and Watersheds
ing the growing season, it is likely that the area is a
wetland. The growing season is defined as the peri-
od between the last killing frost of spring and the
first killing frost in the fall. The period of satura-
tion necessary to form wetland soils can be quite
short. Part of the ongoing debate about wetland
definition concerns the length of time soil should be
saturated in order for a particular site to be consid-
ered a wetland. Periods ranging from seven days to
30 days during the growing season have been sug-
gested. Currently, the 1987 definition for jurisdic-
tional wetlands, using a period of 15 consecutive
days of saturation or seven consecutive days of in-
undation, is recognized by EPA and the Corps.
Although wetlands and saturated soils generally
occur in low-lying areas and natural depressions,
this is not always the case. In some cases, wetlands
can occur on slopes adjacent to springs or in areas
where an impermeable subsurface layer of clay or
bedrock interferes with groundwater infiltration.
The presence of saturated soils (hydric soils) is an
indication of the presence of a wetland. Soil color
and odor can be used as indicators of poorly drained
soils. Soils that are frequently saturated tend to
have a gray to black color and may exude an un-
pleasant "rotten egg" odor. The presence of particu-
lar plant species can indicate the presence of a wet-
land, although wetland determinations can rarely
rely exclusively on the presence or absence of plant
species. Relatively few plants live exclusively in
wetlands (so-called obligate wetland species) and it
is, therefore, difficult to use plants alone as indica-
tors. Illustrated guides to wetland plants are avail-
able from a variety of sources. Some of these source
materials are listed in the bibliography. Appendix
E lists common Georgia wetland plant species.
Design and Construction Considerations for
Wetland Areas and Water Supply Watersheds
The landowner or developer who is considering
developing a property containing wetlands is faced
with a number of challenges. If alteration of the
wetland is necessary, the first challenge is acquir-
ing a permit from the Corps of Engineers (and, in
the case of coastal marshlands, from DNR) prior to
construction.
It is often easier to obtain a permit if the pro-
posed activity is designed in such a way as to keep
impacts to a minimum. Creative site designs that
take into account the form and function of wetlands
and minimize negative impacts are more likely to
be accepted by permitting agencies. Pre-application
meetings with the permitting agencies can be inval-
uable and used as opportunities for receiving valua-
ble suggestions on site design.
The following discussion focuses on aspects of site
design and construction that can be used to pre-
serve wetlands while utilizing the maximum poten-
tial of a site. It should be noted that these tech-
niques are equally applicable to development within
water supply watersheds, which are discussed in
more detail in a later section of this book.
Cluster Development
Accommodation of wetlands in a site design does
not necessarily imply a large reduction in overall
floor area or density. One method for preserving
overall density of a proposed development while
preserving open space is cluster development. This
technique involves concentrating structures on the
Georgia Department of Community Affairs
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Landowners' Guide to Wetlands and Watersheds
TYPICAL CLUSTER DEVELOPMENT
In areas where highlands are isolated by intervening wetlands, one method of
minimizing the amount of wetlands damaged or destroyed by development is by clustering
development on highlands. In the illustration above, lots have been gathered on the hills
and a vegetated buffer between developed sites and the wetlands has been preserved. A
vegetated buffer between a developed site and a wetland slows stormwater runoff into the wetlands
and filters out pollutants. Leaving natural vegetation in place enhances the visual appeal of the site.
Figure 9
Page 10
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upland areas of the property at a higher density
than would normally be allowed (see Figure 9). In
cases where zoning regulations exist, the developer
may also be awarded a "density bonus"; however,
cluster development is not always allowed under lo-
cal zoning regulations. The landowner or developer
should be thoroughly familiar with local land use
regulations prior to the design phase of a contem-
plated construction project. This will save time and
help avoid costly plan revisions.
Cluster development coupled with site-sensitive
design will allow the developer to preserve and
work around wetlands, thus lessening development
impacts and usually simplifying the permitting pro-
cess. Often there are the additional benefits of min-
imizing the cost of infrastructure, such as water
and sewer lines and the amount of cut and fill re-
quired during construction. Clustering of develop-
ment also minimizes the amount of impervious sur-
face in the development, thereby lessening
stormwater runoff and non-point source pollution.
Post-construction problems with flooding and other
water-related problems may also be minimized.
A residential development in Atkinson, New
Hampshire provides an illustration of how cluster
development can be used to preserve wetlands. The
project consists of 98 townhouses gathered on up-
land portions of the site, with 90 acres preserved as
open space. Destruction of wetlands at the site was
limited to roads that crossed the wetlands at rela-
tively narrow points. The developer was able to
keep wetland destruction below ten acres.
The preserved wetlands in a cluster development
provide attractive open space which enhances the
Georgia Department of Community Affairs
Landowners' Guide to Wetlands and Watersheds
overall appearance and value of the site. In addi-
tion, the open space can be used for recreation,
with the construction of walkways or paths around
the wetlands to make them more accessible. In
some cases, preserved wetlands can also provide
a buffer between the property and surrounding
development.
Preservation of Natural Vegetation
The preservation or construction of a vegetated
buffer between a development and a wetland is an
effective way of ensuring that the wetland's ability
to process pollution is not overwhelmed by in-
creased stormwater runoff from developed sites.
Vegetation slows runoff, acts as a pollution filter
and stabilizes soil to prevent excessive erosion (see
Figure 10). Buffers generally range from 25 to 100
feet in width. Georgia's Erosion and Sedimentation
Control Act requires a minimum setback of 25 feet.
Buffers should be larger in areas with steep slopes,
minimal natural vegetation, low soil permeability,
or shallow soil depth.
The preservation of as much natural vegetation
as possible can often reduce costs of construction,
provide a more interesting landscape and preserve
habitat for local species. Vegetation can be threat-
ened by adjacent construction even if the developer
wishes to preserve it. It is often damaged or de-
stroyed through compaction of the soil by construc-
tion equipment. This can best be avoided by
carefully delineating areas to be preserved, using
flagging (brightly colored plastic tape tied to vegeta-
tion to be preserved), signage, or fences. Additional-
ly, the builder should avoid using preserved vege-
tated areas as storage depots for construction
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Landowners' Guide to Wetlands and Watersheds
material. The compaction of soil that results from vation should not extend beneath the tree's canopy
the weight of some materials kills tree root systems (see Figure 11).
as effectively as outright removal of the soil. When
excavating near trees, it is a general rule that exca- Vegetated buffers have been prominently fea-
VEGETATED BUFFERS
A vegetated buffer between a developed site and a wetland slows stormwater runoff into
the wetland and filters out pollutants. Leaving natural vegetation in place enhances the visual appeal
of the site by making the landscape more varied and interesting, and provides habitat for local species.
Figure 10
Page 12
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tured in many developments. One example is the
award-winning design of McCormick Woods, a resi-
dential development in Port Orchard, Oregon. In
Landowners' Guide to Wetlands and Watersheds
this case, the developer preserved a 100-foot buffer
of native vegetation between on-site wetlands and
the development's golf course. In addition, a wild-
PRESERVATION OF TREES
When attempting to
preserve a tree, any
excavation near the
tree should not
extend beneath the
tree's canopy.
Otherwise, vital root
systems are likely to
be damaged or
destroyed, leading to
the death of the tree.
r* •»- . /'
Storing building materials beneath
trees scheduled for preservation
can lead to compaction of soil
over vital root systems and the
inadvertent destruction of the
trees.
Georgia Department of Community Affairs
Figurell
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Landowners' Guide to Wetlands and Watersheds
life sanctuary was established and restrictive cove- Runoff, Erosion and Sedimentation
nants were used to protect wildlife from predatory
pets and to limit the use of pesticides and fertilizer. A number of techniques can be used to reduce or
redirect runoff caused by the development of a site
RUNOFF, EROSION AND SEDIMENTATION
r :-'W -v-v
t^ **> j **0
X
Detention and retention ponds, swales, berms, and sediment fences can be used to
accommodate runoff and sediment from the construction site.
Figure 12
Page 14
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Landowners' Guide to Wetlands and Watersheds
and trap sediment before it reaches wetlands or
other water bodies. Grassed swales, berms, reten-
tion depressions and detention ponds can be used to
slow runoff, allowing much of it to soak into the
ground or to evaporate (see Figure 12). As far as
practicable, the site design should conform to the
natural contours of the land and drainage struc-
tures should correspond to natural drainage pat-
ROADWAY DRAINAGE
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Wi'V Wr^TT^r,,Trr —* w A.-
Impervious surfaces, such as buildings, paved roads, drainage systems using pipes and curb and
gutter, speed runoff. Grassed swales and drainage channels lined with rip-rap slow runoff and
allow some stormwater runoff to infiltrate the soil.
Georgia Department of Community Affairs
Figure 13
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Landowners' Guide to Wetlands and Watersheds
terns. Impervious drainage structures, including
curb and gutter, storm drains and pipes increase
stormwater runoff. Grassy swales or drainage
ditches lined with rip-rap increase runoff to a much
smaller degree than impervious drainage infra-
structure (see Figure 13). In the case of the McCor-
mick Woods Project, on-site lakes, ponds and
streams were enlarged to control runoff and ero-
sion. Retention ponds are often landscaped and
preserved as permanent detention structures in site
design (see Figure 14).
At Post Chastain, an apartment complex near At-
lanta, more than half the site was left undeveloped.
In addition, a detention pond was constructed to
store post-development runoff and more than
100,000 native wetland plants were planted.
Erosion from a construction site that is close to a
wetland can have severe impacts due to increased
sedimentation. Appropriate measures must be ta-
ken to avoid such damage. Under the Georgia Ero-
sion and Sedimentation Control Act, local govern-
ments are empowered to adopt ordinances govern-
ing land-disturbing activities within their
boundaries. If the local government has not adopt-
ed these regulations, the state is responsible for en-
forcement of the Act.
A number of commonly used techniques can be
employed to prevent sediment from an adjacent
construction site from degrading a wetland. Mea-
sures include silt fences to halt sediment before it
reaches the wetland and berms to direct and slow
runoff. In cases where land is excavated but not
immediately built upon, temporary vegetation
should be planted on exposed subsoil to minimize
Page 16
erosion. For large projects, it is generally a good
idea to phase construction, thereby reducing the
amount of land exposed at a particular time.
DETENTION PONDS
Sediment retention ponds are sometimes
preserved as permanent stormwater detention
structures. Landscaping these structures can
provide attractive open space in a development.
Figure 14
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Landowners' Guide to Wetlands and Watersheds
Minimizing Damage When Wetlands are Filled
In cases where impacts to wetlands are unavoida-
ble, a number of techniques can be used to mini-
mize the damage. Willingness to use these tech-
niques may make it easier to acquire a Section 404
permit. A permit must be obtained from the Corps
of Engineers prior to starting construction. The
permitting process is discussed in some detail in the
next section.
A common problem when developing a site con-
taining wetlands is access to all developable areas
on the site. Uplands are often isolated by an inter-
CONSTRUCTION OF BRIDGES
Bridges should cross wetlands at their narrowest
points and should cross at right angles.
Figure 15
Georgia Department of Community Affairs
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Landowners' Guide to Wetlands and Watersheds
vening wetland. This make it necessary to con-
struct roads that cross the wetland in order to make
all upland areas accessible. These points of access
should be located at the narrowest possible points
and entrances and exits should be kept to a mini-
mum. Bridges, rather than embankments, should
be used to cross wetland areas. Bridges should also
be constructed at right angles to the wetland to re-
duce the area of impact (see Figure 15).
Several construction strategies and techniques
can be employed to minimize disruption. For exam-
ple, when heavy equipment is moved through the
wetland, large mats designed to withstand and
more evenly distribute the weight of earth moving
equipment can be laid down over soggy soil to mini-
mize compaction of the soil.
In areas that serve as important breeding
grounds and nurseries for fish or shellfish, dis-
charges into spawning areas during spawning sea-
sons should be avoided. Large projects should be
built in phases, minimizing the amount of unvege-
tated soil present at a particular time, thereby les-
sening the amount of sediment being washed into
the wetland. Sometimes, temporary dikes can be
constructed to dry out a wetland while construction
takes place.
Preservation, Restoration and Creation of
Wetlands
In some cases, a Section 404 permit may be
granted with the condition that compensation for
wetlands destroyed during construction take place
through restoration or enhancement of other wet-
lands. In rare cases, there may be a requirement
Page 18
that new wetlands be created. However, this can be
a complicated and expensive process and some con-
troversy exists concerning the success of such ef-
forts. The complexity of ecological and hydrologic
systems within wetlands makes the creation of such
systems difficult. Environmental consultants with
experience in the field of wetland restoration are
available and a list of these consultants can be pro-
vided by the U.S. Army Corps of Engineers District
Office in Savannah. The U.S. Department of Agri-
culture and the Soil Conservation Service have pub-
lished an Engineering Field Handbook that in-
cludes a chapter on wetland restoration,
enhancement and creation.
Preservation of on-site wetlands is always the
preferred option, although preservation of all wet-
land acreage is not possible in many cases. In the
case of the Chapel Hill subdivision, a 500-acre
planned unit development in Douglas County, the
developer's site design avoided many of the wet-
lands in the area and set aside a 25-acre beaver
wetlands area as an open space amenity for the
community.
If it proves impossible to avoid all wetlands, the
next preferred option is restoration of wetlands that
have been degraded. Degradation may come
through the use of wetlands as dumping areas for
garbage and other waste, by overwhelming wetland
systems with nutrients carried by agricultural or
other runoff, or through removal of vegetation. Res-
toration may be as simple as removing debris and
other sources of pollution, or may be a more compli-
cated process, involving revegetating an area with
naturally occurring plant species or replacing con-
taminated soil. It is recommended that this type of
-------
work be carried out with the aid of a qualified envi-
ronmental consultant.
The case of Southpark, an industrial park near
Ellenwood, offers a good example of wetland resto-
ration as a required mitigation strategy. The site
design required that 4.5 acres of wetland be filled.
As a mitigation measure, the developer was allowed
to restore eight acres of wetland at another site, in
Henry County. In cases where restoration is re-
quired, a 2:1 ratio is commonly, but not exclusively,
used.
Federal and State Wetland Regulations
In recognition of the public value of wetlands, cer-
tain activities in wetlands are regulated by the
government. The federal government regulates the
discharge of fill material into wetlands through Sec-
tion 404 of the Clean Water Act and Section 10 of
the Rivers and Harbors Act of 1899. Restrictions on
conversion of wetlands to agricultural uses are in-
cluded in the so-called "swampbuster provisions" of
the 1990 amendments to the Food Securities Act.
Under the Coastal Marshlands Protection Act,
Georgia regulates activities that would alter the
state's tidal wetlands through a joint application
program with the Corps of Engineers.
Federal Clean Water Act of 1977
The most important federal regulation for wet-
land protection is the Clean Water Act of 1977.
Section 401 of the Act requires states to certify that
any federally permitted activity that impacts wa-
ters of the state will not result in a violation of state
water quality standards. Section 401 permitting is
Georgia Department of Community Affairs
Landowners' Guide to Wetlands and Watersheds
administered by the Georgia Department of Natural
Resources through its Environmental Protection Di-
vision. The acquisition of a water quality certifica-
tion is generally a prerequisite for receiving a per-
mit to develop in a wetland area.
Section 404 of the Act requires a permit from the
Corps of Engineers for activities that involve the
discharge of dredge or fill material into wetlands
adjacent to navigable waterways and isolated wet-
lands one acre or more in size. In Georgia, this pro-
gram is administered by the Corps regional office in
Savannah. The U.S. Environmental Protection
Agency regional office in Atlanta is in charge of en-
forcing the wetland provisions of the Clean Water
Act in Georgia.
The Corps and EPA use the following definition of
wetlands in administering Section 404 permitting:
"Those areas that are inundated or saturated by
surface or groundwater at a frequency and duration
sufficient to support, and that tinder normal circum-
stances do support, a prevalence of vegetation typi-
cally adapted for life in saturated soil conditions.
Wetlands generally include swamps, marshes, bogs
and similar areas." A detailed and highly technical
manual is used to determine if a particular site fits
this general description. As a result, an accurate
wetlands determination must be made by a repre-
sentative of the Corps of Engineers or by a private
consultant deemed qualified by the Corps. When
the delineation has been performed by a consultant,
the Corps is still required to verify the results.
Presently, a pilot program for training biologists
and engineers to perform wetland delineations is
being conducted by the Corps in a few states. If the
program proves successful, the procedure for wet-
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Landowners' Guide to Wetlands and Watersheds
lands delineation should be made less cumbersome
and time-consuming in the near future.
A number of permissible activities under the
provisions of Section 404 are noteworthy. Normal
agricultural, silvicultural and ranching activities,
including plowing, seeding and harvesting, are all
permissible activities as long as they are part of an
existing and ongoing operation. Activities that
would convert an existing wetland to a new agricul-
tural or developmental use are not permissible
without a permit.
In addition to exemptions for normal agricultural
and silvicultural activities, a Section 404 permit is
not required for the maintenance of existing struc-
tures, such as minor drainage ditches and the con-
struction of irrigation ditches and farm and logging
roads, if there are no cumulative impacts on wet-
lands as a result of these maintenance activities.
The use of best management practices (BMPs) for
forest and agricultural road construction and main-
tenance is required by the Clean Water Act in order
to qualify for this exemption (See Appendix F). The
Georgia Forestry Commission has also published a
guide to the use of Best Management Practices in
forested wetlands, which is cited in the reference
section of this guidebook.
The Permitting Process
Nationwide, the Corps of Engineers receives ap-
proximately 11,000 applications a year for Section
404. Of these applications, approximately three
percent are denied. Another 14 percent are with-
drawn by the applicants during the permitting pro-
Page 20
cess. One-third of the applications are modified in
order to address the concerns of the Corps and other
federal agencies. Approximately 400 dredge and fill
permit applications are made in Georgia each year.
The majority of these are for nationwide permits,
regional permits, or individual permits for minor
construction.
In an effort to streamline the permitting and re-
view process, the Corps issues four types of permits:
letters of permission, nationwide permits, regional
permits and individual permits. A detailed discus-
sion of the Section 404 permitting process, along
with suggestions on ways to expedite the process, is
provided in Appendix A.
Letters of Permission
The Corps may grant a letter of permission for ac-
tivities that would result in only a small impact on
wetlands. These activities can gain approval by the
Corps quickly because they are not required to go
through the usual review process.
Nationwide Permits
The Corps has approved 40 nationwide permits
for common activities that will have only a moder-
ate impact on wetlands (see Appendix B). Activities
that fall within specific categories, such as bank
stabilization and temporary construction and ac-
cess, can qualify for a nationwide permit. The most
widely used nationwide permit is Nationwide Per-
mit 26, which can be issued for activities involving
the filling of less than ten acres of wetlands. A pro-
ject must meet one of several criteria in order to
qualify for Permit 26. These criteria include
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wetlands located adjacent to that portion of the
stream that is above the headwaters. Headwaters
are defined as the portion of the stream with an an-
nual average flow of less than five cubic feet per
second (cfs). Activities that adversely affect histori-
cal or archeological resources pursuant to Section
106 of the National Historic Preservation Act can-
not qualify for nationwide permits. Activities that
qualify for a nationwide permit do not have to go
through the regular review process and can be ap-
proved in a short period of time. No public notice is
required when a project qualifies for Permit 26.
Regional Permits
Regional permits are issued by the Savannah of-
fice of the Corps and remain in effect for five years,
unless the Corps feels that more than minor im-
pacts are involved. In these cases, the Corps may
opt to review the permit within a shorter period.
Currently, there are eleven outstanding regional
permits (see Appendix C). A wide range of activi-
ties have been covered by regional permits, includ-
ing road and bridge construction, public boat ramp
construction and placement of public water intakes.
Individual Permits
Projects that may have a substantial impact on
wetlands must receive an individual permit. All
applications for individual permits must go through
the public interest review process (see Figure 16).
Federal and state agencies and the general public
will have an opportunity to comment on the appli-
cation and in some cases, a public hearing will be
held. The Corps will then use a set of criteria to de-
termine if the project is in the public interest. The
Georgia Department of Community Affairs
Landowners' Guide to Wetlands and Watersheds
OVERVIEW OF THE
404 PERMIT PROCESS
APPLICANT SUBMITS
ENGINEER FORM 4345
TO REGIONAL CORPS,
OFFICE WITHIN 15
DAYS. THE DISTRICT!
ENGINEER WILL r
DETERMINE IF THE
APPLICATION IS
COMPLETE {F
COMPLETE, A PUBLIC
NOTICE WILL BE
ISSUED.
15 TO 30 DAY PERIOD
FOR COMMENTS FROM
1) CORPS
2> OTHER FEDERAL
AGENCIES
3) STATE AGENCIES
4) LOCAL AGENCIES
5) SPECIAL INTEREST
GROUPS
6) INDIVIDUALS
EVALUATION BASED ON: CONSERVATION;
ECONOMICS, AESTHETICS; GENERAL WELFARE; FISH
A WILDLIFE VALUES; HISTORIC ft ARCHEOLOGICAL
SITE VALUES; FLOOD CONTROL; RECREATION;
LAND USE; WATER SUPPLY: WATER QUALITY;
NAVIGATION; FOOD PRODUCTION.
'applicant signs
APPROVAL AND
RETURNS TO
v CORPS WITH FEE
APPLICANT ADDRESSES
CONDITIONS PRIOR TO
APPROVAL
FOR EVERY PERMIT ISSUED. THE
CORPS PREPARES AN ENVIRONMENTAL
ASSESSMENT AND STATEMENT OF
FINDING
Figure 16
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Landowners' Guide to Wetlands and Watersheds
Environmental Protection Agency plays a large role
in the review process and has the power to veto a
decision made by the Corps.
Georgia Coastal Marshlands Protection Act
A permit must be obtained from the State of
Georgia for activities that alter coastal marshlands.
Coastal marshlands are defined as any marshland
or saltmarsh "lying within a tide elevation range
five and six-tenths (5.6) feet above mean tide level."
A determination of whether a particular property
includes coastal marshlands can be performed by
the Coastal Resources Division of DNR, located in
Brunswick.
Activities that are regulated include the dredg-
ing, filling and draining of these marshlands. The
building of private walkways or docks by the own-
ers of adjacent high land does not require a permit
if the structures do not obstruct the flow of water.
In addition, some activities of the federal govern-
ment, the Georgia Department of Transportation,
local governments, public utilities and railroad
companies are exempt from coastal marshlands
regulation.
Most activities in coastal marshlands also require
a Section 404 permit from the Corps. A joint appli-
cation can be filed with the State of Georgia and the
Corps for projects in coastal marshlands. All appli-
cations will be reviewed by the Coastal Marshlands
Protection Committee at a public meeting. The ap-
plicant must show that the proposed activity is not
contrary to the public interest and that there are no
alternative sites for the project.
Page 22
The Section 404 Permitting Process
Following a determination that wetlands are
present at a site, the next step is accurate mapping
of wetland boundaries. Delineation of the wetlands
can be carried out by a representative of the Corps.
There is a long waiting list for wetland determina-
tions, so many landowners prefer to hire a Corps
approved independent consultant to make the de-
termination. Although final determination must be
carried out by the Corps, submittal of a report by a
qualified consultant will ensure that a request for
delineation of wetlands receives priority. In such
cases, the Corps will generally "spot check" the con-
sultant's determination rather than reproducing the
consultant's work in detail.
The next step in the process is the submission of
a preliminary site plan to the Corps. Projects that
qualify for letters of permission, nationwide per-
mits, or regional permits may be exempted from
submission of a complete application. Projects that
do not qualify for a letter of permission, nationwide
or regional permit require an individual permit.
It is strongly suggested that a pre-application
meeting with Corps representatives be scheduled.
This will allow an exchange of ideas concerning the
project and can reveal ways of addressing potential
problem areas that the developer had not previously
considered. Inclusion of interest groups likely to
have objections to the project can also facilitate the
process and lessen objections that may be raised
once the application has been made. This proved to
be a very effective strategy in the case of the Cross-
roads Business Center, located in Savannah. This
development is a mixed-use business/industrial cen-
-------
ter sited on 1,784 acres of woodlands. Under a re-
vision of the definition for jurisdictional wetlands in
1989, the site was found to be approximately 85
percent wetlands. Pre-application meetings with
the Corps and with representatives of environmen-
tal interest groups led to the design of a mutually
acceptable site plan and helped avoid a lengthy and
potentially costly battle over the project.
A two-page form, Engineering Form 4345, must
be submitted to the Corps district office when ap-
plying for an individual permit. Information must
be provided about the type of activity planned, the
purpose of the activity, names and addresses of
adjoining property owners and a list of other au-
thorizations required by federal, state and local
agencies. In addition, a vicinity map, a plan view
and an elevation or cross-sectional view must be
submitted.
Within 15 days, the Corps will issue a public no-
tice of the application and a period of 30 days will
be reserved for comment by the public, interest
groups, and federal, state and local agencies. A
public hearing on the application can be requested
by any individual, interest group, or agency that
comments on the application.
After the public review process is completed, the
Corps will make a decision on the application. The
district engineer can issue a permit, request that
certain conditions be met or revisions be made to
the site plan as a prerequisite to permit issuance,
or deny the permit. It is important to note that the
Environmental Protection Agency may veto Corps
decisions on permit applications, and the Advisory
Council on Historic Preservation must be afforded
Georgia Department of Community Affairs
Landowners' Guide to Wetlands and Watersheds
an opportunity to comment on any activity that
would affect an archeological site or historic
building.
A "statement of findings" or "record of decision"
will be issued by the district engineer. A fee of $10
is charged for non-commercial projects and a fee of
$100 is charged for commercial projects when the
permit is issued.
For a more detailed discussion of the 404 permit-
ting process, see Appendix A. Methods for expedit-
ing the permitting process and a discussion of the
requirements of Georgia's Coastal Marshland Pro-
tection Act are included.
The Food Securities Act of 1985 and the Food,
Agricultural, Conservation and Trade Act of
1990
The Food Securities Act of 1985 and the Food, Ag-
ricultural, Conservation and Trade Act of 1990 in-
clude certain provisions with respect to wetlands
that are commonly referred to as the "swampbuster
provisions." Under these provisions, eligibility for
all U.S. Department of Agriculture (USDA) pro-
grams is denied to farms that convert wetlands to
croplands. These programs include USDA crop sup-
port payments, disaster payments, crop insurance,
Farmers Home Administration loans, Commodity
Credit Corporation storage payments, farm storage
facilities loans, Conservation Reserve Program pay-
ments and other programs under which payments
are made to the farmer with respect to commodities
produced. The U.S. Soil Conservation Service per-
forms wetland determinations on lands receiving
USDA benefits.
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Landowners' Guide to Wetlands and Watersheds
Watershed Protection
What is a Watershed?
A watershed is the total drainage basin of a river
or stream (see Figure 17). Major streams are often
used as sources for municipal water supplies and
impoundments and reservoirs are commonly con-
structed for that purpose. The protection of water
quality within the watershed is, therefore, of consid-
erable importance to public health and welfare.
Over 50 percent of all Georgians get their drinking
water from rivers and reservoirs. The area of a wa-
tershed that occurs upstream of a public water in-
take is known as a "water supply watershed. Wa-
ter supply watersheds are particularly important in
north and central Georgia, where surface water is
WHAT IS A WATERSHED?
A watershed is the total drainage area
of a stream. In the illustration to the
right, the boundaries of the watershed
are delineated by the ridge lines to the
east, west, and north of the river. The
streams of the watershed originate on
the slopes of the ridges.
A water supply watershed is a water-
shed used as a public water source.
The "critical area." of the water supply
watershed is the portion of the water-
shed located within a 7-mile radius
upstream of a public water intake.
Development upstream of a public
water intake, chiefly from non-point
source pollution, can have severe
impacts on water quality.
Figure 17
Page 24
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the primary source of water (see Figure 18).
Why Should Watersheds Be Protected?
Intensive development of land within a water-
shed can have severe consequences for water qual-
ity and can increase the costs of treatment. Source!
of pollution may be so-called "point sources," which
are discrete and relatively easy to identify, such as
discharge from a wastewater treatment facility, or
GEORGIA'S WATER
SUPPLY WATERSHEDS
Figure 18
Georgia Department of Community Affairs
Landowners' Guide to Wetlands and Watersheds
may be "nonpoint sources," which are difficult to
pinpoint because they consist of pollutants that col-
lect over broad areas and are carried to water bo-
dies by stormwater runoff (see Figure 19). Non-
point source pollution is increased by development
because the pollution sources increase and because
impervious surfaces, such as roads, driveways and
parking lots prevent infiltration of stormwater into
the soil and accelerate the rate of runoff. These sur-
faces accumulate thin veneers of pollution from au-
tomobile exhausts, crankcases and other sources
that are carried into streams and reservoirs by
stormwater runoff.
The undeveloped areas ofa watershed provide a
large, permeable surface into which some stormwa-
ter runoff infiltrates. Additionally, low areas in the
watershed act as retention ponds, slowing runoff.
Runoff is further slowed by the presence of vegeta-
tion, which functions as a natural filter for pollu-
tants. The increased amount of impervious surface
(structures and pavement) associated with develop-
ment disrupts these processes. Rain falling on
these surfaces may be carried directly into the wa-
ter body without being slowed by plants and reten-
tion areas. This results in higher water levels than
would otherwise occur and increases the chances of
flooding in downstream areas. It also increases ero-
sion and sedimentation.
How to Determine if Your Property is Located
in a Water Supply Watershed
The majority of water supply watersheds are lo-
cated in the mountain and piedmont regions of the
state. Local governments within the state's coastal
plain rely much more heavily on groundwater re-
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Landowners' Guide to Wetlands and Watersheds
sources as their sources for public water. By state
definition, the area extending seven miles upstream
of a water supply intake is a "vital area" requiring
greater protection than the remainder of the wa-
tershed. Maps of water supply watersheds may be
available at the regional development centers.
Planning criteria for water supply watersheds
have been established by the Georgia Department
of Natural Resources, to be used by local govern-
ments when developing their comprehensive plans.
These criteria include a series of recommended limi-
tations on development. Many local governments
COMMON SOURCES OF NON-POINT
SOURCE POLLUTION
Page 26
Figure 19
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Landowners' Guide to Wetlands and Watersheds
have chosen to adopt these criteria as policies with-
in their comprehensive plans and to incorporate
them into their land use regulations. Therefore, it
is important to become familiar and comply with lo-
cal development regulations with respect to water
supply watersheds.
The criteria differentiate between "large" water
supply watersheds, which have an area equal to or
greater than 100 square miles, and "small" water
supply watersheds, which encompass less than
that. For both large and small watersheds, the cri-
teria vary between the "critical area," which lies
within a seven-mile radius of the intake or reservoir
SETBACKS WITHIN WATER SUPPLY
WATERSHEDS
In large water supply watersheds, impermeable surfaces should not be placed within
100 feet of a perennial stream and 150 feet of a reservoir. For small water supply
watersheds, a distance of 150 feet between impervious surfaces and the waterbody
should be maintained inside the "critical area" (within a seven-mile radius of the intake)
and 75 feet outside it.
Figure 20
Georgia Department of Community Affairs
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Landowners' Guide to Wetlands and Watersheds
and the remainder of the watershed. Within the
seven-mile radius, the development limitations for
both large and small water supply watersheds call
for a natural or enhanced vegetative buffer, with a
setback of 100 feet from the banks of a perennial
stream and a setback of 150 feet from a reservoir,
measured from the normal bank elevation. No im-
pervious surfaces are allowed within a 150 foot set-
back from the water resource. Within the setback,
septic tanks and septic fields are prohibited (see
Figure 20). Operations involving the transport,
handling, or storage of hazardous materials must
be performed on an impermeable surface with spill
and leak collection systems approved by DNR.
For small water supply watersheds, there are ad-
ditional criteria for the watershed outside the se-
ven-mile radius. The setback for impervious sur-
face in this area is 75 feet and the vegetative buffer
width is 50 feet. The total impervious surface with-
in a small water supply watershed cannot exceed 25
percent. Septic tanks and drainfields cannot be in-
stalled within 100 feet of the banks. In addition,
there are criteria for landfills and hazardous waste
and disposal sites. New municipal landfills are re-
quired to have synthetic liners and leachate collec-
tion systems. New hazardous waste treatment and
disposal facilities are prohibited and existing facili-
ties are required to perform their operations on im-
permeable surfaces with spill and leak collection
systems approved by DNR.
Developing Property in a Watershed
There are a number of actions that can be taken
to reduce the impact of development on watersheds.
For example, many communities have adopted reg-
Page 28
ulations that prohibit new development from ex-
ceeding pre-development levels of pollution loading
and stormwater runoff. However, this perfor-
mance standards" approach is not always practical
for a local government, particularly if local govern-
ment personnel lack the expertise or equipment
necessary to monitor development for compliance.
Another approach places restrictions on actions that
are likely to have detrimental impacts on water
quality. This is the approach reflected by the DNR
criteria for water supply watersheds. It has the ad-
vantage of simplicity in monitoring and enforce-
ment. The following list illustrates this approach.
1 The portion of the site covered by impervious sur-
faces should be minimized. As previously dis-
cussed, buildings and paved surfaces cover the land
and prevent rainwater from seeping into the
ground, resulting in increased stormwater runoff.
Some local governments regulate the percentage of
a site in a watershed that may be covered by imper-
vious surfaces. DNR planning criteria recommend
that no more than 25 percent of the total surface
area of a water supply watershed be covered by im-
pervious surface. One way to preserve desired over-
all floor-area while avoiding an increase of impervi-
ous surface is through the use of multiple stories for
buildings.
Parking lots and driveways often account for a
large proportion of the impervious surface in an
area. Parking areas that use gravel or other porous
material are preferable to asphalt or concrete in
this respect. In some cases permeable pavement
can be used for driveways, patios and walkways.
2. Runoff from a site should be controlled and re-
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Landowners' Guide to Wetlands and Watersheds
duced. Assuming that the area downslope of an im-
pervious surface is already vegetated, it should be,
as far as practicable, left undisturbed as a buffer for
stream channels or other water bodies. Vegetation
effectively slows runoff and allows more of it to infil-
trate the soil. Grassed swales can also be used to
PHASING DEVELOPMENT
Erosion and sedimentation can be minimized by phasing large projects.
In cases where it is necessary to remove natural vegetation and expose soil for a
lengthy period of time, grass should be planted over the exposed area.
Figure 21
Georgia Department of Community Affairs
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Landowners' Guide to Wetlands and Watersheds
slow runoff. These channels can be used in conjunc-
tion with retention basins (See Figure 12). Sedi-
ment ponds are often constructed to hold runoff
during construction. These ponds can be incorpo-
rated into the site design as a permanent, attrac-
tive amenity. In areas with steep slopes, runoff can
be reduced by the construction of terraces. As with
sediment ponds, these terraces can be designed and
landscaped in an attractive fashion that enhances
the overall site design. Buildings and other imper-
vious surfaces should be set back from stream chan-
nels and reservoirs. Locally required setbacks may
vary and the developer should check with the local
government for these and other requirements.
3. The risk of point source pollution should be mini-
mized. Land uses involving the handling, storage
or manufacture of toxic chemicals should be avoided
in watershed areas. If above-ground storage tanks
for toxic materials are constructed, they should
have spill and leak collection systems. Large stor-
age tanks should also have secondary containment
capable of containing 110 percent of the volume of
the tank.
4. Soil erosion in watersheds should be minimized.
Virtually any construction involves some removal of
natural vegetation and excavation. This increases
erosion and can have severe impacts on water qual-
ity in nearby streams. Generally, local govern-
ments have regulations that are designed to mini-
mize erosion from construction sites.
As in the case of wetlands protection, a number
of measures can be taken to reduce erosion and sed-
imentation. These include the use of silt fences to
prevent sediment from leaving the site, construc-
Page 30
tion of temporary berms to collect and channel run-
off and the construction of sediment basins to act as
reservoirs for runoff and sediment. When graded
surfaces are to be exposed for a considerable
amount of time, planting grass or other temporary
vegetation can minimize erosion. Phasing large
projects, so that a minimum of erodable soil is ex-
posed at a particular time, can also be effective (see
Figure 21).
Conclusion
This guidebook has explained what wetlands and
water supply watersheds are and why they should
be protected, how the permitting process for devel-
opment in wetlands works and techniques of design
and construction that can be used to minimize the
negative impacts of development upon wetlands
and water supply watersheds. It is our hope that
the information provided will aid the landowner
and small-scale developer in avoiding potentially
expensive delays in the acquisition of permits while
promoting the preservation of these ecologically im-
portant environments.
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APPENDIX A
A Guide to the Section 404 Permitting
Process and Georgia Coastal Marshlands
Protection Act
Delineation of Jurisdictional Wetlands
After it has been established that wetlands are
likely to be present at a site, a formal determina-
tion and delineation must be carried out by the
Corps of Engineers prior to the beginning of a pro-
ject. A request form, accompanied by a map show-
ing the location and boundaries of the property,
must be submitted to the Corps district office. A
member of the Corps staff will visit the site and
identify the portions that are jurisdictional wet-
lands subject to Section 404. The Corps receives a
large number of requests and there is often a long
waiting list for jurisdictional determinations. Time
can be saved if a preliminary wetlands determina-
tion is made by a professional consultant. While
this cannot take the place of an official determina-
tion made by the Corps, requests that include a pre-
liminary determination are given priority. The con-
sultant should be familiar with the Corps wetlands
delineation manual and the 404 permitting process.
A list of qualified consultants in Georgia who will
conduct wetlands determination is available from
the Corps office in Savannah. A list of the mini-
mum requirements for wetlands determinations is
also available from the Corps regional office. The
Corps staff will review the preliminary determina-
tion and will decide to accept it or to conduct their
own determination.
Following a determination that wetlands are
present, a preliminary site plan should be submit-
Georgia Department of Community Affairs
Landowners' Guide to Wetlands and Watersheds
ted to the Corps. The Corps may not require
submission of a complete application for projects
that qualify for letters of permission, nationwide
permits or regional permits. A letter stating the
basic information about the proposed activity may
be sufficient.
If a project does not qualify for a letter of permis-
sion, nationwide permit, or regional permit, an indi-
vidual permit must be obtained. It is strongly sug-
gested that a pre-application meeting with the
Corps be requested. At the meeting, the applicant
will have the opportunity to explain the site plans
and the Corps will have an opportunity to respond
to the plan and explain concerns. Modifications to
the site plan designed to bring the plan into compli-
ance with Corps guidelines can be made following
the pre-application meeting.
Submittal of a Permit Application
The individual should submit a formal applica-
tion for the appropriate permit. A two-page form
(Eng. Form 4345), available from the Corps office in
Savannah, serves as the application. The applica-
tion must include a description of the activity, the
purpose of the activity, names and addresses of ad-
joining property owners, a list of authorizations re-
quired by other agencies (federal, state and local)
and other important information adequate for pub-
lic notice. Three maps, including a vicinity map, a
plan view and an elevation and/or cross-sectional
view, must be included with the application. De-
tailed engineering plans and specifications are not
required.
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Landowners' Guide to Wetlands and Watersheds
Application Review Process for Individual
Permits
Fifteen days after an application is received, the
Corps will issue a public notice of the application.
Following public notice, a period of 30 days will be
reserved for comments on the application. The ap-
propriate local government, the state Department
of Natural Resources, the U.S. Fish and Wildlife
Service, the National Marine Fisheries Service and
the Environmental Protection Agency will have the
opportunity to submit comments to the Corps. In-
terested individuals and groups will also have the
opportunity to submit comments on the application.
In order for an application to be approved, the Geor-
gia Department of Natural Resources must certify
that the project will comply with state water quali-
ty standards.
Any individual or government department can re-
quest that the Corps hold a public hearing on the
application. Public hearings are typically sche-
duled for projects that would have a large impact on
wetland areas. At the hearing, the applicant has an
opportunity to present plans for the proposed activi-
ty and to respond to any concerns raised at the
meeting. Following the comment period, the appli-
cant is given an opportunity to respond to the con-
cerns that have been raised. The applicant may
wish to modify the plans for the project in order to
further address concerns.
Review Criteria
The Corps of Engineers uses a variety of criteria
to evaluate an application, including the following:
Page 32
L The proposed project must be the least environ-
mentally damaging and most practicable alterna-
tive. All alternatives, including different locations
and site plans, must be considered. Undeveloped
sites that are not presently owned by the applicant
must be considered.
2. A development that is not water-dependent will
not be approved by the Corps unless the applicant
can clearly demonstrate that there are no alterna-
tives to the site and the site plan.
3. The development must not contribute to the sig-
nificant degradation of water quality.
4. Twenty evaluation factors are used to determine
if the project is in the public interest. These include:
Conservation
Flood Hazards
Water Conservation
Economics
Floodplain Values
Energy Needs
Aesthetics
Land Use
Safety
Environmental Concerns
Navigation
Food Production
Wetlands Impacts
Erosion/Accretion
Public Welfare
Historic Properties
Recreation
Mineral Needs
Fish/Wildlife Values
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Water Quality/Supply
5. In the case of a large project, the Corps may re-
quire the applicant to compensate for the wetlands
that are destroyed. This can be done by the restora-
tion or enhancement of other, generally adjacent,
wetlands or, in rare cases, creation of new wet-
lands on the site or a nearby site. Compensation
can include the enhancement or restoration of an
existing wetland that has been altered by previous
development. The preservation of existing wet-
lands can also be viewed as appropriate compensa-
tion in some cases.
Decision
After the public review process has been complet-
ed, the Corps District Engineer will make a deci-
sion on the application. The District Engineer can
decide to issue a permit, issue a permit with condi-
tions, or deny a permit. The EPA is authorized to
veto the Corps decision to grant a permit. A fee of
$10 for a noncommercial use and $100 for a com-
mercial use is charged for issuance of a permit. The
District Engineer will prepare a "statement of find-
ings" or, in cases where an environmental impact
statement has been prepared, a "record of decision."
These will include the district engineer's views of
the project impacts.
Simplifying the 404 Permitting Process
L Obtain a wetlands determination from the Corps
or from a private consultant prior to development of
a site plan. An early determination is likely to save
time and money.
Georgia Department of Community Affairs
Landowners' Guide to Wetlands and Watersheds
2. The preferred option is to avoid activities that
would involve the discharge of dredge or fill materi-
als into wetlands, thus negating the need for under-
going the sometimes lengthy permitting process.
3. If the filling of wetlands cannot be avoided, try to
minimize the impact on the wetland. A commit-
ment to minimizing the impact of development to
wetlands will more likely result in a successful per-
mit application.
4. After preliminary plans have been formulated,
contact the Corps of Engineers to determine which
permit will be needed for your plan. For larger pro-
jects, request a pre-application meeting with the
Corps to discuss site plans.
5. Address the review criteria in your application.
For example, show that the plan is the least envi-
ronmentally damaging, practicable alternative
available.
Georgia's Coastal Marshlands Permitting Pro-
cess
Prior to developing in a coastal marshland, con-
tact the Coastal Resources Division of the Depart-
ment of Natural Resources in Brunswick. A deter-
mination of the existence and extent of the
marshlands can be made by a member of the staff.
A pre-application meeting can be held to discuss the
plans for the property. Such a meeting may involve
a site visit by a member of the Division staff. The
staff will generally work with the applicant to come
up with a plan that is acceptable to the applicant
and to the Division.
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Landowners' Guide to Wetlands and Watersheds
When the plans for the site have been formalized,
a complete application for a coastal marshlands
permit must be submitted. The application form
can be obtained from the Ecological Services Sec-
tion of the Coastal Resources office in Brunswick.
The application must include a location map, draw-
ings of the plan and a copy of the deed to the prop-
erty. The completed application should be submit-
ted to the DNR office in Brunswick. An application
fee of $25 for every acre of marshland to be affected
is used to fund the administration of the permitting
program.
In the vast majority of situations, an activity that
requires a state permit will also require a federal
404 permit. A copy of the state application can be
submitted to the Corps of Engineers. If the project
will involve the use of state owned marshlands, the
applicant must get approval from DNR. A cover
letter and a copy of the full application must be sub-
mitted to the Real Estate Unit of DNR in Atlanta.
In some cases, the Corps of Engineers will re-
quire that a water quality certification be obtained
from the Environmental Protection Division of
DNR. A list of addresses and telephone numbers of
important state and federal agencies is included in
Appendix D.
The Review Process
The application will be reviewed by DNR's Coast-
al Marshlands Protection Committee in a public
meeting. This committee is composed of the Com-
missioner of Natural Resources and two citizens
from Georgia's coastal counties. The staff of the
Coastal Resources Division will make a recommen-
Page 34
dation on the application to the Committee. The ap-
plicant will then have the opportunity to present
the proposal to the Committee.
The Committee uses the following criteria to eval-
uate an application:
L In most cases, activities that are not water depen-
dent will not be approved.
2. A permit will generally not be granted unless
there are no alternative upland sites available for
the project.
3. The Committee uses three additional criteria to
determine if a proposed activity is in the "public in-
terest." The activity must not obstruct the flow of
navigational water. The activity must not lead to
increased erosion, the shoaling of channels or the
creation of stagnant waters. The activity must not
interfere unreasonably with natural resources such
as marine life, other types of wildlife and water and
oxygen supply.
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Landowners' Guide to Wetlands and Watersheds
APPENDIX B
Nationwide Permits under Section 404 of the Clean Water Act
* 401 water quality certification not required.
** 401 general certification denied, individual certification required.
Water
Nationwide
Oualitv
Permit
Cert,
Puroose
1
*
Aids to navigation
2
*
Structures in artificial canals
3
2745
Maintenance
4
2745
Fish and wildlife harvesting, enhancement and attraction devices and
activities
5
2745
Scientific measurement devices
6
2725
Surveying activities
7
2745
Outfall structures
8
*
Oil and gas structures
9
*
Anchorage structures
10
*
Mooring buoys
11
*
Temporary recreational structures
12
2664
Utility line backfill and bedding
13
2665
Bank stabilization
14
2732
Minor road crossings
15
2667
U.S. Coast Guard approved bridges
16
2668
Return water from upland contained disposal areas
17
**
Hydropower projects
18
2733
Minor discharges
19
*
Dredging activities involving 25 cubic yards or less
20
2745
Oil Spill Cleanup
21
**
Surface coal mining activities
22
2745
Removal of vessels
Georgia Department of Community Affairs
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Landowners' Guide to Wetlands and Watersheds
(CONTD)
Water
Nationwide Quality
Permit Cert. Purpose
23 2734 Approved categorical exclusions
24 * State administered Section 404 programs
25 2745 Structural discharge
26 2671 Headwaters and isolated wetlands
27 2745 Wetland and riparian restoration and creation projects
28 * Modifications to existing marinas
32 2745 Completed enforcement actions
33 2727 Temporary construction, access and dewatering
34 ** Cranberry production
35 * Maintenance dredging of existing basins
36 2745 Boat ramps where there is no discharge into wetlands
37 2745 Emergency watershed protection and rehabilitation
38 2672 Cleanup of hazardous and toxic waste
40 2673 Farm buildings
Source: U.S. Army Corps of Engineers, Savannah District,
P.O. Box 889
Savannah, GA 31402-0889
Page 36
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Landowners' Guide to Wetlands and Watersheds
APPENDIX C
Current and Pending Regional Permits in Georgia
Date Expiration
GeoerraDhic Area
Issued
Date
Activity Authorized
1. State of Georgia
1-18-85
1-18-95
Fill for roads and bridges
2. Chatham County
6-29-76
10-8-96
Private, single family docks
3. Camden County
11-5-76
2-1-97
Private, single family docks
4. Glynn County
11-22-76
2-1-97
Mosquito control
5. Chatham County
12-31-83
12-30-95
Private, single family docks
6. Bryan County
2-28-83
8-31-93*
Private, single family docks
7. Liberty County
6-28-84
10-8-96
Private, single family docks
8. Mcintosh County
3-31-84
10-8-96
Private, single family docks
9. State of Georgia
9-22-90
9-22-95
Public boat ramps
10. Atlantic Ocean
2-5-90
8-27-00
Placement of materials to improve/expand existing
DNR artificial reefs
11. Georgia Coast
10-30-89
10-30-99
Artificial fishing reefs
12. George F. Andrews Lake,
2-5-88
2-5-93*
Minor work and structures
Allatoona Lake, West
Point Lake, Lake Sidney
Lanier, Carters Lake
~Reissuance Pending
Georgia Department of Community Affairs
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Landowners' Guide to Wetlands and Watersheds
APPENDIX C
(CONTINUED)
Date Expiration
Issued Dflte
13. Lake Blackshear 5-8-90 5-8-95
Pending Regional Permits
Geographic Area
1. Lake Blue Ridge
2. Lake Blue Ridge
3. Lake Blue Ridge
4. Lake Blue Ridge
Activity Authorized
Noncommercial piers, docks, and boathouses; aerial
utility lines; limited dredging
Initial dredging, less than 1000 cubic yards
Maintenance dredging of less than 300 cubic yards
Noncommercial boathouses/hoists, piers
Riprap and bulkheads
Page 38
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APPENDIX D
Important addresses and telephone numbers
Section 404 Permits
U.S. Army Corps of Engineers
Savannah District
Regulatory Branch
P.O. Box 889
Savannah, GA 31402-0889
(912)652-5347
(800)448-2402
Environmental Protection Agency (E.P.A.)
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
(404)347-2126
State Water Quality Certification
Water Quality Certification
Environmental Protection Division
Georgia Department of Natural Resources
205 Butler Street SE
Floyd Towers - East, Room 1070
Atlanta, GA 30334
(404) 656-4887
Coastal Marshlands Permits
Georgia Department of Natural Resources
Ecological Services Section
Coastal Resources Division
One Conservation Way
Brunswick, GA 31523-8600
(912) 264-7218
Georgia Department of Community Affairs
Landowners' Guide to Wetlands and Watersheds
Highly Erodible Land and Wetland Provisions of the
1985 and 1990 Farm Bills
USDA - Soil Conservation Service
Robert G. Stephens Federal Building
P.O. Box 13
355 East Hancock Avenue
Athens, GA 30601-2769
(706)546-2214
Sensitive Land Certification & NWI Wetland Maps
Georgia Department of Natural Resources
EPD - Geologic Survey - Map Sales
Agriculture Building
19 Martin Luther King Drive, SW
Atlanta, GA 30334
(404)656-3214
National Historic Preservation Act - Section 106
Georgia Department of Natural Resources
Office of Historic Preservation
205 Butler Street SE
Suite 1462
Atlanta, GA 30334
(404)656-2840
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A Landowners' Guide to Wetlands and Watersheds
APPENDIX E
Common Plants Found in Georgia's Wetlands
Qommoni(Plant|_^^n^in!^^lWetlan^
Saltmarsh cordgrass (Spartina alterniflora)
Needlerush (Juncus roemerianus)
High tide bush (Iva frutescens)
Saltmeadow cordgrass (Spartina patens)
Big cordgrass (Spartina cynosuroides)
Saltgrass (Distichlis spicata)
Coast dropseed (Sporobolus virginica)
Bigelow glass wort (Salicornia bigelovii)
Woody glasswort (Salicornia virginica)
Saltwort (Batis maritima)
Sea lavender (Limonium nashii)
Sea oxeye (Borrichia frutescens)
Silverling (Baccharis halimifolia)
False willow (Baccharis augustifolia)
Cgmmg^^l^t|jndT^gs^2an^jn!£ig|hw|ter_
Wetiands
Trees
Bald cypress (Taxodium distichum)
Pond cypress (Taxodium ascendens)
Swamp tupelo (Nyssa aquatica)
Swamp blackgum (Nyssa biflora)
Carolina ash (Fraxinus caroliniana)
Planer tree (Planera aquatica)
Black willow (Salix nigra)
Hazel alder (Alnus serrulata)
Pond pine (Pinus serotina)
Page 40
Shrubs
Buttonbush (Cephalanthus occidentalis)
Sweetspire (Itea virginica)
Fetterbush (Lyonia lucida)
Ferns
Royal fern (Osmunda regalis)
Netted chain fern (Woodwardia areolata)
Virginia chain fern (Woodwardia virginica)
Herbaceous Plants
Bulrush (Scirpus sp.)
Bur-reed (Sparganium sp.)
Lizard's tail (Saururus cernuus)
False nettle (Boehmeria cylindrica)
Arrowhead (Sagittaria sp.)
Pitcher plant (Sarracenia sp.)
Switchcane (Panicum sp.)
Spikerush (Eleocheris sp.)
Rush («Juncus sp.)
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Landowners' Guide to Wetlands and Watersheds
APPENDIX F
BEST MANAGEMENT PRACTICES FOR FARM, FORESTRY, LOGGING
AND MINING ROADS IN WETLAND AREAS OF THE UNITED STATES
1. Permanent roads (for farming or forestry
activities), temporary access roads (for mining,
forestry, and farming), and skid trails (for
logging) [adjacent to or crossing] waters of the
United States shall be held to the minimum
feasible number, width, and total length
consistent with the purpose of specific farming,
silvicultural or mining operations, and local
topographic and climatic conditions;
2. All roads, temporary or permanent, shall be
located sufficiently far from streams or other
water bodies (except for portions of such roads
that must cross waterbodies) to minimize
discharges of dredged or fill material into
waters of the United States;
3. The road fill shall be bridged, culverted, or
otherwise designed to prevent the restriction of
expected flood flows;
4. The fill shall be properly stabilized and
maintained to prevent erosion during and
following construction;
5. Discharges of dredged or fill material into
waters of the United States to construct a road
fill shall be made in a manner that minimizes
the encroachment of trucks, tractors,
bulldozers, or other heavy equipment within
waters of the United States (including adjacent
wetlands) that lie outside the lateral boundaries
of the fill itself;
6. In designing, constructing, and maintaining
roads, vegetative disturbance in the waters of
the United States shall be kept to a minimum;
7. The design, construction, and maintenance of
the road crossing shall not disrupt the
migration or other movement of those species of
aquatic life occupying the water body;
8. Borrow material shall not be taken from upland
sources unless this is unavoidable;
9. The discharge shall not take, or jeopardize the
continued existence, of threatened or
endangered species as defined under the
Endangered Species Act, or adversely modify or
destroy the critical habitat of such species;
10. Discharges into breeding and nesting areas for
migratory waterfowl, spawning areas, and
wetlands shall be avoided if practical
alternatives exist;
11. The discharge shall not be located in the
proximity of a public water supply intake;
12. The discharge shall not occur in areas of
concentrated shellfish production;
13. The discharge shall not occur in a component of
Georgia Department of Community Affairs
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Landowners' Guide to Wetlands and Watersheds
the National Wild and Scenic River System;
14. The discharge of material shall consist of
suitable material free from toxic pollutants in
toxic amounts; and,
15. All temporary fills shall be removed in their
entirety and the area restored to its original
elevation.
Source: U.S. Army Corps of Engineers
Savannah District
P.O. Box 889
Savannah, GA 31402-0889
Page 42
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Landowners' Guide to Wetlands and Watersheds
REFERENCES
General Sources
Are There Wetlands on My Properly? A Guide for the Developer, Annapolis, Maryland: Maryland
Department of Natural Resources, 1992.
Brockman, C.F., Trees of North America, Racine, Wisconsin: Western Publishing Co., Inc., 1979.
Cowardin, L.M., et al., Classification of Wetlands and Deepwater Habitats of the United States,
Washington, D.C.: United States Fish and Wildlife Service, 1979.
Cowie, Gail M. and Cooley, James L., Watershed Protection: A Guidebook for Georgia, Athens, Georgia:
Institute of Community and Area Development, University of Georgia, 1988.
Cowie, Gail M. and Cooley, James L., Watershed Protection: Building a Local Program, Athens, Georgia:
Institute of Community and Area Development, University of Georgia, 1989.
Developer's Handbook for Freshwater Wetlands, Charleston, South Carolina: U.S.Army Corps of
Engineers and South Carolina Coastal Council, 1992.
How to Recognize a Nontidal Wetland, Maryland Department of Natural Resources, Annapolis, Maryland.
Kundell, James E. and Woolf, S. Wesley, Georgia Wetlands: Trends and Policy Options, Athens, Georgia:
Carl Vinson Institute of Government, The University of Georgia, 1986.
Kusler, J.A., Our Wetland Heritage: A Protection Guidebook, Washington, D.C.: Environmental Law
Institute, 1983.
Mitsch, W.J. and Gosselink, J.G., Wetlands, New York: Van Nostrand Reinhold Co., 1986.
Recognizing Wetlands, U.S. Army Corps of Engineers, 1992.
Robins, C.R., Ray, G.C. and Douglass, J., A Field Guide to Atlantic Coast Fishes of North America,
Boston: Houghton Mifflin Co., 1986.
Simkins, Hampton, Coder, Kim D. and Lewis, George, Wetlands Heritage of Georgia, Athens,Georgia:
Georgia Department of Community Affairs
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Landowners' Guide to Wetlands and Watersheds
Cooperative Extension Service, The University of Georgia College of Agriculture, 1991.
Steinberg, Robert E., Wetlands and Real Estate Development Handbook, Rockville, Maryland: Government
Institutes, Inc., 1991.
Development Techniques
Best Management Practices for Forested Wetlands in Georgia, Macon, Georgia: Georgia Forestry
Association, 1990.
Devereaux, William, Natural Causes, Builder, July 1991.
Kusler, Dr. Jon A., Our National Wetland Heritage: A Protection Guidebook, Environmental Law
Institute, 1983.
Salvesen, David, Wetlands: Mitigating and Regulating Development Impacts, Washington, D.C.: The
Urban Land Institute, 1990.
Government Regulation
Blount, Gregory W., From Marshes to Mountains, Wetlands Come Under State Regulation, Mercer Law
Review, vol. 41,1990.
How to Expedite the 404 Process of the Clean Water Act (Draft), Savannah, Georgia: U S Armv Corns nf
Engineers, Savannah District, January 1992. 6 y 01
Interim Guidance for Wetlands Protection, Raleigh, North Carolina: North Carolina Department of
Environment, Health and Natural Resources, 1992.
Kundell, James E. and Woolf, S. Wesley, Georgia Wetlands: Values, Trends and Legal Status Mpivai- T
Review, vol. 41,1990. 'iVAercer ^aw
Kundell, James E., et al., Management of Georgia's Marshlands Under the Coastal Marshlands
Protection Act of 1970, Athens, Georgia: Carl Vinson Institute of Government, Universitv of
Georgia, 1988. ' y
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