The 1990 Corps and EPA Mitigation Memorandum of Agreement provides that the mitigation <br /> sequence of avoidance, minimization, and compensatory mitigation "is considered satisfied where the <br /> proposed mitigation is in accordance with specific provisions of a Corps and EPA approved <br /> comprehensive plan that ensures compliance with the compensation requirements of the Section <br /> 404(b)(1) Guidelines" (MOA, Part 11.C). <br /> 3. Minimization of adverse impacts is accomplished for isolated wetlands. <br /> 4. The conceptual compensatory mitigation design will provide the framework for the <br /> compensatory mitigation required in conjunction with the Letters of Permission. <br /> 5. The public interest review requirement for the filling of wetlands designated in the Plan as <br /> "developable" is satisfied. <br /> B. Actions Preceding Implementation of Alternative Processing Procedure: <br /> 1. The Corps will suspend the application of all General Permits within the Plan area, except <br /> for Nationwide Permit 3 (Maintenance), 5 (Scientific Measurement Devices), 27 (Wetland Restoration <br /> Activities), and 32 (Completed Enforcement Actions) (33 CFR 330.2 et seq.). <br /> 2. The West Eugene Wetland Conservation Plan must be approved by DSL, the Corps and <br /> EPA. Corps and EPA approval would depend upon DSL approval of the Plan, including any terms <br /> and conditions established by DSL in its approval order. <br /> 3. Consultation required by Section 7 of the Endangered Species Act will be completed for the <br /> wetlands included in the Plan. U.S. Fish and Wildlife Service has indicated that one listed plant <br /> species, Bradshaw's lomatium (Lomatium bradshawii), may occur in the Plan area. Several other <br /> species which are candidates for listing may also occur. A biological assessment addressing the <br /> potential effects on these species of filling wetlands designated for development is being prepared and <br /> will be provided to U.S. Fish and Wildlife Service in compliance with the Act. <br /> C. Proposed Alternative Permitting Procedure for the West Eugene Wetland Conservation Plan <br /> Area: <br /> • The alternative permitting procedure begins with the City of Eugene's review of individual wetland fill <br /> proposals. After the applicant has surveyed and field- staked the wetlands proposed for filling which <br /> are designated as developable in the Plan, and has submitted a proposal to the City of Eugene's Permit <br /> and Information Center, the City will review the proposal for conformance with the Plan, minimization <br /> (where required), and compensatory mitigation. <br /> Minimization Determination. The City will examine the proposed activity against Plan <br /> impact minimization standards and guidelines. For projects proposed in wetlands that are small and <br /> hydrologically isolated, the minimization determination will be advisory only. Ways to minimize <br /> impacts will be identified and the applicant will be advised of the benefits to be gained from <br /> minimizing impacts, including reduced mitigation costs. For projects proposed for wetlands that are <br /> part of a larger wetland complex and that may have both existing and future functional value, the <br /> applicant will be advised of ways to minimize impacts and will be required to incorporate practicable <br /> minimization measures into their project proposals. Actions taken by the applicants to minimize <br /> impacts will be documented on the site plan maps. <br /> 2 <br />