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12/2/98
Wetland Delineators Beware!

USEPA Region III recently issued a three-ring binder booklet of field
indicators of hydric soils in the Mid-Atlantic states, ostensibly taken from
Version 3.2 of Field Indicators of Hydric Soils in the US by NRCS.  The
undated USEPA document does not excerpt Version 3.2 (July 1996).  It is
internally inconsistent, offering many sketches of field indicators which
contradict its text, not to mention errata that will be obvious to those
familiar with the various editions of the national list.

Users seeking to field test indicators of hydric soils will be wise to use the
national list (Version 4.0 is expected from NRCS in March 1998) and avoid
entirely the confusions of the USEPA Region 3 document, at least until such
time as it is competently edited and its many substantive problems rectified.

My detailed comments letter to USEPA (16 p.), is attached as the ASCII file
MIDATLAN.TXT.  I would appreciate any one else's comments.

James A. Schmid
Schmid & Company, Inc., Consulting Ecologists
jaschmid@aol.com





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Schmid & Company, Inc., Consulting Ecologists
1201 Cedar Grove Road
Media, Pennsylvania  19063-1044
10 February 1998

Ralph J. Spagnolo
US Environmental Protection Agency  Region III
841 Chestnut Street
Philadelphia, Pennsylvania  19107

In re:  Field Indicators of Hydric Soils in the Mid-Atlantic US

Dear Mr. Spagnolo:

This letter is to ask questions and provide comments on the undated Mid-A=
tlantic Field Indicators document that I recently received.  For some yea=
rs I have been commenting on the many successive drafts of the national l=
ist of field indicators based on my field experience, which is primarily =
in the Mid-Atlantic states.  There clearly is a need for more reliable te=
chnical guidance on how to recognize hydric soils in the field than exist=
s in either the 1987 Corps manual or the 1989 joint federal manual for we=
tland identification.

Your task in defining precisely the limits of descriptive features that d=
efine hydric soils is a difficult and important one.  It results from the=
 shift of long-term attention away from identifying typical, characterist=
ic examples of named soil series and toward defining the limits of landsc=
ape boundaries that have regulatory significance.  Evidently it is going =
to be years before there is a reliable body of information on which confi=
dent determinations of hydric soils can be based.  For field use it is mu=
ch more important to have clear parameters against which a given soil sam=
ple can be measured, and a replicable regulatory conclusion reached, than=
 that the parameters be perfect in themselves.  New indicators can be int=
roduced from time to time when they have been clearly defined and tested.=
  In the meanwhile, regulatory decisions are going to be made.  Any field=
 indicators document should seek to facilitate that process.

Your booklet on Mid-Atlantic soils is a disturbing document which display=
s less than careful attention to detail in its preparation, is filled wit=
h internal contradictions, and which likely will have only limited practi=
cal utility.  I hope that my comments and questions will prove helpful as=
 you prepare a replacement document, because there is a genuine need for =
a document of this sort.  It has been gratifying to observe increasing pr=
ecision in the national indicators over the years.  It is disappointing t=
o see the apparent step backward represented by this Mid-Atlantic documen=
t.  It is perplexing why you could not circulate a draft document and at =
least get the most obvious errors corrected prior to undertaking a rather=
 costly printing at the public's expense.  The public deserves better, an=
d it has a right to expect higher quality in a document for which it has =
paid a substantial price.

The comments below begin with general remarks and proceed to specific com=
ments on substantive indicators.  I proceed in the order of presentation =
in your document.


General Comments

Your Mid-Atlantic document at present is misleading and borders on being =
incomprehensible.  Users thoroughly familiar with the various editions of=
 the national list may be able to guess at some of what you may have inte=
nded to write.  But no one will be able to use this document for any purp=
ose in the field without major revisions.

Your Errata sheet is woefully inadequate.  It does identify several evide=
nt errors, but it needs to be vastly expanded to identify all recognizabl=
e errata.  It probably would be simpler to just scrap the existing docume=
nt and start over.

The purpose of your document is not clear from the text.  It apparently i=
s intended to be a partial reprint of the national list of field indicato=
rs of soils that formed under hydric conditions in some part of the easte=
rn United States.  Oddly, no mention of any version of the national list =
appears in your references, although you claim on the cover to have excer=
pted Version 3.2.  Your text and graphics, however, are greatly at odds w=
ith Version 3.2.  At minimum, if you choose to ignore previous versions, =
you should cite Version 3.2 (July 1996) and Version 3.3 (December 1996), =
subsequent changes during 1997, and Version 4.0 (expected March 1998).  I=
t is puzzling as to why your document does not clearly state that the rec=
ognition of field indicators is expected to be an ongoing process for man=
y years.  It is not obvious that there is enough new information in your =
Mid-Atlantic document to warrant its publication separate from the nation=
al list.  Is your document clearly intended to be different from the nati=
onal list in its substantive directives regarding how hydric soils are to=
 be recognized?  If so, you should not claim on the cover that it consist=
s of "excerpts" from the national list Version 3.2.  If you are putting o=
ut this document for preliminary "testing," then you should say so, altho=
ugh it is ill-designed for "testing" by comparison with the national list=