Fort Island Final Report - Tranzon · Guide to the Natural Communities of Florida. 1990. Florida Natural Areas Inventory and the Florida Dept. of Natural Resources. Tallahassee, FL.

FINAL REPORT

for

FORT ISLAND RESIDENTIAL LOTS FD-09-0301544-001

FORMAL DETERMINATION OF THE LANDWARD EXTENT OF WETLANDS AND

OTHER SURFACE WATERS

STATE OF FLORIDA

DEPARTMENT OF ENVIRONMENTAL PROTECTION

Division of Water Resource Management

Office of Submerged Lands and Environmental Resources

Wetland Evaluation and Delineation Section

Prepared by

Jay Kamke, John Humphries, Matthew Harris, and Charlie Bidwell

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TABLE OF CONTENTS FINAL REPORT Page Number Formal Determination .......................................................................................................3 Site Location ....................................................................................................................4 Project Area Description ..................................................................................................6 Wetland Boundary Delineation .........................................................................................8 References .......................................................................................................................9 FIGURES Figure 1: Location of Fort Island Residential Lots, Citrus County, Florida……………...5

Figure 2: Soils Map for Fort Island Residential Lots, Citrus County, Florida…………...7 TABLES Table 1: Plant Community and Soil Profile Descriptions ........................................ 10-18 Table 2: Wetland Delineation Tests ...............................................................................19 Table 3: Hydrologic Indicators ......................................................................................19 Table 4: Hydric Soil Indicators ......................................................................................20 Table 5: Wetland Definition ..........................................................................................20 Table 6: Uniform Mitigation Assessment Method .................................................. 21-22 ATTACHMENTS Attachment A: Aerial Photograph and Cerified Survey Delineating Boundaries of Area Inspected and Landward Extent

of Wetlands and Other Surface Waters of the State ............... Map Pocket

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Final Report for

Fort Island Residential Lots Formal Determination of Landward Extent of Wetlands and Other Surface Waters

(FD –09-0301544-001) Formal Determination A field inspection of the above referenced property was conducted by the authors; Jay Kamke, Matthew Harris, John Humphreys, and Charlie Bidwell; and Gary Exner of Advantage Consulting, LLC representing the petitioner. The landward extent of wetlands and surface waters of the State subject to the wetland resources jurisdiction of the Florida Department of Environmental Protection (FDEP) for the Fort Island Residential Lots property is delineated on the aerial photocopy/certified survey appended as Attachment A (Map Pocket). The bold black line demarcates the boundary of the area inspected. The red hatched area represents the landward extent of wetlands and other surface waters of the State subject to the wetland resources jurisdiction of the FDEP in accordance with Rule 62-340, F.A.C. (Table 2) wetlands or other surface waters of the State within the wetland resources jurisdiction of the FDEP. The wetland boundary line was flagged by the Department and subsequently surveyed by the petitioner.

Photo 1: Coastal Hammock in the northeast corner of the property.

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Site Location The property for which the formal determination was requested is an irregularly shaped parcel of seventy-one acre property located in Sections 17, 18, and 20, Township 18 South, Range 17 East, Citrus County (Figure 1). The property extends north of County Road 44 (Fort Island Trail) between West Pinebark Lane to the east and West Chickasaw Lane to the west.

Photo 2: Old dock in the northeast corner of the property.

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Project Area Description The property is located within the Gulf Coastal Lowlands Physiographic Province and both the Basinger-EauGallie-Myakka and Homosassa-Weekiwachi-Durbin general soil associations of Citrus County. The property is contiguous on both sides, east and west, by man-made canals with residential houses bordering them including boat access. The northeast corner of the property is occupied by a Live Oak-Redcedar-Cabbage Palm coastal hammock and the remains of an old homestead including a dock (Photo 2). Saltwater marsh comprise the tidally influenced Crystal River floodplain with a fringe of mixed hardwood swamp and flatwoods on the ecotones. There are secondary woods and spoil piles in the uplands adjacent to the canals. The eastern portion of the property is mostly Cabbage Palm flatwoods and hammock while the middle and western portion of the property is Saw Palmetto flatwoods and hammock. The wetland/upland interface on most of the property has an abrupt slope, facilitating long hydroperiods and the formation of hydric soil morphologies within the wetland boundaries and the absence of hydric soils landward of the wetland boundary. Additionally, the tidal influence of Crystal River is slowly eroding away under the vegetation of the flatwoods causing saw palmetto rhizomes to extend into the wetlands in some areas as well as tree falls as seen in Photo 3.

Photo 3: Tree fall from shallow rooting in the wetland exposes bare mineral soil.

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Soils A soil survey of Citrus County (1988) has been produced by the United States Department of Agriculture/Soil Conservation Service (USDA-SCS). As of 1994 the USDA-SCS was renamed the Natural Resources Conservation Service (NRCS). The soil survey delineates four map units within the project area boundaries (Figure 2). Two of the mapping units have hydric soils as either a major component or inclusions (Hydric Soils of Florida Handbook, 1995).

Map Symbol Map Unit Name_______________________________________________ 37* Matlacha, limestone substratum-Urban land complex 40** Homosassa mucky fine sandy loam 49** Terra Ceia-Okeelanta association, frequently flooded 58* Myakka, limestone substratum-EauGallie, limestone substratum complex ------------------------------------------------------------------------------------------------------------------- ** Soil Map Unit with greater than 50% of area as hydric soils. * Soil Map Unit with less than 50% of area as hydric soils.

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Wetland Boundary Delineation The landward extent of wetlands and other surface waters of the State was established through ground reconnaissance and photo-interpretation. The wetland boundary was determined by the continual interpretation of vegetation, soils, and hydrologic indicators. The hydrologic contiguity, vegetation and soils were examined at specific points along the entire wetland/upland interface in order to corroborate the positioning of the wetland boundary. Four sites are listed in Table 1; there were five plant communities on site. In Table 1 plant species are listed by common and scientific names (See Plant Taxonomic References) for each stratum (canopy, subcanopy and ground cover). The classification of each plant species pursuant to Section 62-340.450, F.A.C. is also provided. Soil profiles were described on-site to a depth of 12 inches or more from soil borings with an Oakfield probe or from freshly exposed shallow pits dug with a shovel. Hydric soils were identified by the presence of at least one of the soil morphological properties (Table 4) described by Florida Soil Conservation Service, (1992). The wetlands are delineated by the red hatched area on Attachment A.

Photo 4: Hammock in the western portion of property.

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References: Campbell, C. 1983. Systematics of the Andropogon virginicus Complex (GRAMINEAE). J. of Arnold Arboretum. p. 171-254 Correll D.H. 1982. Flora of the Bahama Archipelago. A.R. Gantner, Germany. p. 1692 Florida Soil Conservation Service. 1992. Soil and Water Relationships of Florida's Ecological Communities. Gainesville, FL. p. 20 Gilbert, K., Rick Cantrell, et. al. 1995. The Florida Wetlands Delineation Manual. Published by the Florida Department of Environmental Protection. Tallahassee, FL. p. 198 Guide to the Natural Communities of Florida. 1990. Florida Natural Areas Inventory and the Florida Dept. of Natural Resources. Tallahassee, FL. p. 111 Godfrey, R. 1988. Trees, Shrubs, and Woody Vines of Northern Florida and Adjacent Georgia and Alabama. University of Georgia Press. Athens, GA. p. 734 Godfrey, R. and J. Wooten. 1979. Aquatic and Wetland Plants of Southeastern United States: Monocotyledons. University of Georgia Press. Athens, GA. p.712 Godfrey, R. and J. Wooten. 1979. Aquatic and Wetland Plants of Southeastern United States: Dicotyledons. University of Georgia Press. Athens, GA. p. 933 Hall, D. 1978. Grasses of Florida. Doctoral Dissertation. University of Florida. Gainesville, FL. p. 498 Carlisle, V. W. 2000. Hydric Soils of Florida Handbook. (3rd ed.) Florida Association of Environmental Soil Scientists. Gainesville, FL. p. 319 Lellinger, D. 1985. Ferns and Fern Allies of the United States and Canada. Smithsonian Institute. Washington, D.C. Press. p. 389 Soil Survey of Citrus County, Florida 1988. United States Department of Agriculture-Soil Conservation Service. p. 192 Tobe, J., et. al. 1998. Florida Wetland Plants, an Identification Manual. University of Florida. Gainesville, FL. p. 598

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TABLE 1. Plant Community and Soil Profile Descriptions SITE 1 --Flag no. W-13, Waterward of Wetland Line Plant Community: Coastal Mixed Hardwood Swamp CANOPY

Scientific Name Common Name Indicator status Sabal palmetto cabbage palm FAC Acer rubrum red maple FACW Magnolia virginiana sweetbay OBL Diospyros virginiana common persimmon FAC Liquidambar styraciflua sweetgum FACW Quercus laurifolia laurel oak FACW Ulmus americana American elm FACW

GROUND COVER Scientific Name Common Name Indicator status Acrostichum danaeifolium inland leatherfern OBL Saururus cernuus lizard's tail OBL Crinum americanum southern swamp-lily OBL Toxicodendron radicans eastern poison ivy UPL Chasmanthium latifolium spangle grass FAC Sabal palmetto cabbage palm FAC Smilax tamnoides bristly greenbrier vine Smilax bona-nox saw greenbrier vine Smilax auriculata earleaf greenbrier vine Juniperus virginiana eastern redcedar UPL

Soil Profile Description* Horizon Depth Description

L1 0-4 black (10YR 2/1) muck, 40% inclusion10YR 7/1 fine sand L2 4-9 black (10YR 2/1) muck L3 9-14+ gray (10YR 6/1) fine sand, 20% 10YR 7/1 mottles

Observed water table depth? 10 inches Hydric: Yes, A8 (Muck Presence). A4 (Hydrogen Sulfide) at 10 inches. _____________________________________________________________________ * All depths are in inches and all colors were determined on moist soil. Hydrologic Indicators 7 Evidence of aquatic fauna (crab burrows), 8 Hydrologic Data (Hydrogen Sulfide and Muck), 9 Morphological Plant Adaptations (fluted trunks), 12 Vegetated Hummocks, 13 Water Marks Jurisdiction Wetland? This area passes the A-test, B-test, and D-test Suggested UMAM Score: UMAM scores listed in this report, while substantiated by field work and technical observations, represent the best professional judgment of the WEDS evaluator and are not legally binding. Water Environment: optimal Community Structure: optimal

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Photo 5: Interior of wetland at site 1.

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Photo 6: Crab burrows at site 1.

Photo 7: Raccoon (Procyon lotor) tracks at site 1.

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SITE 2 --Flag no. W-13, Landward of Wetland Line Plant Community: Mesic Mixed Hardwood Hammock CANOPY

Scientific Name Common Name Indicator status Liquidambar styraciflua sweetgum FACW Prunus caroliniana Carolina laurelcherry UPL Ulmus americana American elm FACW Sabal palmetto cabbage palm FAC Quercus virginiana live oak UPL

SUBCANOPY Scientific Name Common Name Indicator status Prunus caroliniana Carolina laurelcherry UPL

GROUND COVER Scientific Name Common Name Indicator status Celtis laevigata sugar-berry; hackberry FACW Oplismenus setarius woods grass FAC Prunus caroliniana Carolina laurelcherry UPL Chasmanthium latifolium spangle grass FAC Quercus virginiana live oak UPL Smilax bona-nox saw greenbrier vine Ipomoea sp. morningglory vine Sabal palmetto cabbage palm FAC Toxicodendron radicans eastern poison ivy UPL Campsis radicans trumpet creeper vine

Photo 8: Plant community at site 2.

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Soil Profile Description* Horizon Depth Description

L1 0-4 gray (10YR 5/1) fine sand L2 4-8 very pale brown (10YR 7/3) fine sand, 30% 10YR 7/4 clay L3 8-12+ brown (10YR 4/3) clay sand

Hydric: No _____________________________________________________________________ * All depths are in inches and all colors were determined on moist soil. Jurisdiction Wetland? No

Photo 9: Cabbage palm hammock plant community at site 2.

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SITE 3 --Flag no. New 4-19 Plant Community: Mixed Wetland Hardwoods CANOPY

Scientific Name Common Name Indicator status Quercus laurifolia laurel oak FACW Sabal palmetto cabbage palm FAC Juniperus virginiana eastern redcedar UPL Celtis laevigata sugar-berry; hackberry FACW

SUBCANOPY Scientific Name Common Name Indicator status Persea palustris swamp bay OBL Myrica cerifera southern bayberry FAC Celtis laevigata sugar-berry; hackberry FACW Juniperus virginiana eastern redcedar UPL Cornus foemina swamp dogwood FACW

GROUND COVER Scientific Name Common Name Indicator status Ilex vomitoria yaupon holly FAC Sabal palmetto cabbage palm FAC Myrica cerifera southern bayberry FAC Pteridium aquilinum western brackenfern UPL Serenoa repens saw palmetto UPL Toxicodendron radicans eastern poison ivy UPL Osmunda cinnamomea cinnamon fern FACW

Photo 10: Landscape of plant community at site 3.

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Soil Profile Description* Horizon Depth Description

L1 2-0 very dark brown (10YR 2/2) hemic L2 0-0.5 black (10YR 2/1) muck L3 0.5-5 dark gray (10YR 4/1) sand L4 5-9 gray (10YR 5/1) sand, 10% 10YR 4/1 and 6/1 mottles L5 9-14+ gray (10YR 6/1) sand, 20% 10YR 4/1 and 5/1 mottles

Hydric: Yes, A8 (Muck Presence). S6 (Stripped Matrix) _____________________________________________________________________ * All depths are in inches and all colors were determined on moist soil. Jurisdiction Wetland? Yes, area passes B-test and D-test. Suggested UMAM Score: UMAM scores listed in this report, while substantiated by field work and technical observations, represent the best professional judgment of the WEDS evaluator and are not legally binding. Water Environment: optimal Community Structure: optimal

Photo 11: Soil profile at site 3.

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SITE 4 --Flag no. New 4-19, Landward of Wetland Line Plant Community: Coastal Hammock CANOPY

Scientific Name Common Name Indicator status Liquidambar styraciflua sweetgum FACW Quercus virginiana live oak UPL Quercus laurifolia laurel oak FACW Pinus elliottii slash pine UPL

SUBCANOPY Scientific Name Common Name Indicator status Quercus laurifolia laurel oak FACW Lyonia fruticosa coastalplain staggerbush UPL

GROUND COVER Scientific Name Common Name Indicator status Myrica cerifera southern bayberry FAC Ilex glabra gallberry UPL Persea palustris swamp bay OBL Acer rubrum red maple FACW Osmunda cinnamomea cinnamon fern FACW Pteridium aquilinum western brackenfern UPL Serenoa repens saw palmetto UPL Liquidambar styraciflua sweetgum FACW Magnolia grandiflora southern magnolia UPL Vaccinium myrsinites shiny blueberry UPL Smilax auriculata earleaf greenbrier vine Vitis rotundifolia muscadine vine

Photo 12: Landscape of plant community at site 4.

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Soil Profile Description* Horizon Depth Description

L1 2-0 very dark brown (10YR 2/2) hemic L2 0-2 dark gray (10YR 4/1) sand L3 2-4 gray (10YR 5/1) sand L4 4-12+ gray (10YR 6/1) sand

Hydric: No _____________________________________________________________________ * All depths are in inches and all colors were determined on moist soil. Jurisdiction Wetland? No

Photo 13: Soil profile at site 4.

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TABLE 2. Wetland Delineation Tests The following are abbreviated versions of the wetland delineation tests of Section 62-340.300, F.A.C. "A Test" [62-340.300(2)(a), F.A.C.] A positive wetland test requires that the aerial extent of obligate plant species is greater than that of the upland plants in the appropriate stratum and hydric soils or hydrologic indicators are present. "B Test" [62-340.300(2)(b), F.A.C.] A positive wetland test requires that the aerial extent of obligate and facultative wet plant species in the appropriate stratum is greater than 80% of the plants in that stratum and hydric soils or hydrologic indicators are present. "C Test" [62-340.300(2)(c), F.A.C.] A positive wetland test requires an affirmative demonstration of specific soil conditions for areas that are not pine flatwoods, improved pastures or drained areas. "D Test" [62-340.300(2)(d), F.A.C.] A positive wetland test requires one or more hydrologic indicators and hydric soils. “Altered Site Test” [62-340.300(3), F.A.C.] Note: See Tables 3 and 4 for a list of the Hydrologic and Hydric Soil Indicators.

TABLE 3. Hydrologic Indicators

The following is an abbreviated version of the various hydrological indicators pursuant to Section 62-340.500, F.A.C. Although not specifically listed in Section 62-301.400, F.A.C., these indicators would be applicable to determinations done under this rule as well. 1. Algal mats 2. Aquatic mosses or liverworts on trees or substrates 3. Aquatic plants 4. Presence of aufwuchs 5. Drift lines and rafted debris 6. Elevated lichen lines 7. Evidence of aquatic fauna 8. Hydrologic data 9. Morphological plant adaptations 10. Secondary flow channels 11. Sediment deposition 12. Presence of vegetated hummocks or tussocks 13. Water marks

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TABLE 4.

Hydric Soil Indicators The following is an abbreviated version of the hydric soil indicators developed by the U.S.D.A.- S.C.S. (Now known as the Natural Resources Conservation Service) for Florida in 1992. A complete explanation of the hydric soil indicators above can be obtained from Florida Soil Conservation Service, (1992). See References. All Soils Loamy and Clayey Soils 1. Hydrogen Sulfide 1. Loamy Gleyed Matrix 2. Stratified Layers 2. Depleted Matrix 3. Organic Bodies 3. Thick Dark Surface (S. FL only) 4. Mucky Mineral 4. Iron/Manganese Masses (N. FL. only) 5. Muck Presence (S. FL. only) 5. Marl (S. FL. only) 6. 1 cm Muck (N. FL. only) 6. Umbric Surface Sandy Soils 1. Sandy Gleyed Matrix 2. Sandy Redox 3. Stripped Matrix 4. Dark Surface

TABLE 5. Wetland Definition pursuant to 62-340.200, F.A.C.

"Wetlands," as defined in subsection 373.019(17), F.S., means those areas that are inundated or saturated by surface water or ground water at a frequency and a duration sufficient to support, and under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soils. Soils present in wetlands generally are classified as hydric or alluvial, or possess characteristics that are associated with reducing soil conditions. The prevalent vegetation in wetlands generally consists of facultative or obligate hydrophytic macrophytes that are typically adapted to areas having soil conditions described above. These species, due to morphological, physiological, or reproductive adaptations, have the ability to grow, reproduce or persist in aquatic environments or anaerobic soil conditions. Florida wetlands generally include swamps, marshes, bayheads, bogs, cypress domes and strands, sloughs, wet prairies, riverine swamps and marshes, hydric seepage slopes, tidal marshes, mangrove swamps and other similar areas. Florida wetlands generally do not include longleaf or slash pine flatwoods with an understory dominated by saw palmetto.

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TABLE 6. Uniform Mitigation Assessment Method

62-345.500 (6) (b) and (c) Community Structure

Optimal (8 – 10): The vegetation community and physical structure provide conditions which support a range from 80% to 100% of the optimal level of function beneficial to the fish and wildlife utilizing the area.

All or nearly all of the plant cover is appropriate and contains desirable species. Invasive exotics are not present. Normal regeneration and natural recruitment are present with typical age and size distribution with normal successional or mortality patterns. Optimal structural habitat is available and plants are in good condition and health. Current land management practices are optimal for long term viability of the plant community. Normal topographic features are present and there is no evidence of siltation or algal growth impediments to the normal aquatic plant growth. Any uplands will provide an optimal level habitat and life history support for fish and wildlife in the associated wetlands or other surface waters.

Moderate (5 – 7): The level of function provided by the plant community and physical structure is limited to a range of 50% to 70% of the optimal level.

Majority of the plant cover is appropriate and contains desirable species. Invasive exotics have minimal cover. Near-normal regeneration and natural recruitment of desirable species are present with approximately the typical age and size distribution with no permanent deviation from normal successional or mortality patterns. Moderate structural habitat is available and desirable plants are generally in good condition and health. Current land management practices are generally appropriate, but causing some shift in the plant community. Moderate topographic features are present and there is minor evidence of siltation or algal growth impediments to the normal aquatic plant growth. Any uplands will provide a moderate level habitat and life history support for fish and wildlife in the associated wetlands or other surface waters.

Minimal (1 – 4): The level of function provided by the plant community and physical structure is limited to a range of 10% to 40% of the optimal level.

Majority of the plant cover is inappropriate and contains undesirable species. Invasive exotics have moderate cover. Minimal normal regeneration and natural recruitment of desirable species are present with atypical age and size distribution with permanent deviation from normal successional or mortality patterns. Minimal structural habitat is available and desirable plants are in generally poor condition and health. Current land management practices are causing partial removal or alteration of natural structures or introduction of some artificial features. Minimal or inappropriate topographic features are present and there is moderate evidence of siltation or algal growth impediments to the normal aquatic plant growth. Any uplands will provide a minimal level habitat and life history support for fish and wildlife in the associated wetlands or other surface waters.

Not Present (0): The vegetation community and physical structure do not provide functions beneficial to the fish and wildlife.

Most of the plant cover is inappropriate and contains undesirable species. Invasive exotics are the dominant cover. Normal regeneration and natural recruitment of desirable species are not present with atypical age and size distribution with dead or dying vegetation. Inappropriate or zero structural habitat is available and plants are in poor condition and health. Current land management practices are causing removal or alteration of natural structures or introduction of artificial features. Topographic features are not present and there is high evidence of siltation or algal growth impediments to the normal aquatic plant growth. Any uplands will provide a little or no habitat and life history support for fish and wildlife in the associated wetlands or other surface waters.

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Water Environment

Optimal (8 – 10): The hydrology and water quality provide conditions which support a range from 80% to 100% of the optimal level of function beneficial to the fish and wildlife utilizing the area.

Water levels and flows are appropriate with the expected water level indicators being distinct and consistent. Soil moisture is appropriate and there is no evidence of soil desiccation, oxidation, or subsidence. Soil erosion or deposition patterns are typical. Evidence of fire history does not indicate atypical fire frequency or severity due to excessive dryness. Vegetation zonation is appropriate and shows no signs of hydrologic stress. Presence or evidence of use by animal species with specific hydrologic requirements is normal. The plant community composition is not characterized by species tolerant or associated with water quality degradation or alterations. Direct observation and existing water quality data indicates no water quality degradation and indicates optimal support of normal ecological values. Water depth, wave energy, currents, and light penetration are optimal.

Moderate (5 – 7): The level of function provided by the hydrology and water quality is limited to a range of 50% to 70% of the optimal level.

Water levels and flows are slightly inappropriate with the expected water level indicators being moderately distinct and consistent. Soils are drier than expected, but there is no evidence of soil desiccation, oxidation, or subsidence. Soil erosion or deposition patterns are slightly atypical. Evidence of fire history does indicate some atypical fire frequency or severity due to excessive dryness. Vegetation zonation is slightly inappropriate and shows some signs of hydrologic stress. Presence or evidence of use by animal species with specific hydrologic requirements is less than expected. The plant community composition consists of some species tolerant or associated with water quality degradation or alterations. Direct observation and existing water quality data indicates slight water quality degradation and indicates moderate support of normal ecological values. Water depth, wave energy, currents, and light penetration are moderate.

Minimal (1 – 4): The level of function provided by the hydrology and water quality is limited to a range of 10% to 40% of the optimal level.

Water levels and flows are moderately inappropriate with the expected water level indicators being minimally distinct and consistent. Soils moisture is inappropriate with strong evidence of soil desiccation, oxidation, or subsidence. Soil erosion or deposition patterns are atypical. Evidence of fire history indicates atypical fire frequency or severity due to excessive dryness. Vegetation zonation is inappropriate and shows signs of hydrologic stress. Presence or evidence of use by animal species with specific hydrologic requirements is greatly reduced from expected. Much of the plant community composition consists of species tolerant or associated with water quality degradation or alterations. Direct observation and existing water quality data indicates moderate water quality degradation and indicates minimal support of normal ecological values. Water depth, wave energy, currents, and light penetration are minimal.

Not Present (0): The hydrology and water quality do not provide functions beneficial to the fish and wildlife.

Water levels and flows are extremely inappropriate with inconsistent or nonexistent water level indicators. Soil moisture is extremely inappropriate with strong evidence of soil desiccation, oxidation, or subsidence. Soil erosion or deposition patterns are greatly atypical. Evidence of fire history indicates a high deviation from the typical fire frequency or severity due to extreme dryness. Vegetation zonation is greatly inappropriate and shows strong signs of hydrologic stress. Presence or evidence of use by animal species with specific hydrologic requirements is lacking. The plant community composition consists predominately of species tolerant or associated with water quality degradation or alterations. Direct observation and existing water quality data indicates significant water quality degradation with adverse ecological effects. Water depth, wave energy, currents, and light penetration are inappropriate.