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Ecologist defends wetland delineation and says mitigation will yield a net functional gain
Summary
Senior ecologist Ryan Kahlo testified that October delineations followed Corps guidance using primary and secondary hydrology indicators, that disputed data points do not meet wetland criteria, and that the mitigation plan (including converting low‑functioning lawn to native plantings and open‑graded docks) yields a net functional gain exceeding impacts.
Ryan Kahlo, a senior ecologist testifying for the project, told the hearing that the wetland delineation and rating work complied with Corps of Engineers methodology and used primary and secondary hydrology indicators appropriate for late‑October fieldwork.
Kahlo said reliance on secondary indicators is standard where surface evidence is limited: "We applied secondary indicators consistently throughout the site," he testified. He said a WETS three‑month wetness index classified October 2023 as "normal" for the region and that October delineations are allowable under federal guidance.
On contested field data points, Kahlo disputed claims that DP9 or DP13 should be reclassified as wetlands. He noted that while DP9 shows a Sandy Redox soil indicator, it lacked hydrophytic…
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