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assigned a wetland type.This basin,however,exhibits the same vegetation conditions as that of both Basins 1 and 2 described above. SER has determined that Basins 1 and 2 should be reclassified as (P-) type wetlands exhibiting emergent (-EM-) vegetation with a saturated (-B-) moisture regime that is ditched (-d) or Type 2 (PEMBd)wetlands. SER would classify Basin 3 as a Type 2(PEMBd)wetland as well,based on the same conditions as described above for Basins 1 and 2. For a comparison of Type 2 and Type 3 wetlands, refer to the Circular 39 description of these two types published by the Fish and Wildlife Service. Also,below is an excerpt from a technical paper, written by Frank Svoboda, that offers a clarification of the Cowardin classification and Circular 39 Wetland Types 1, 1L, 2, 3 and 7. The full version of this paper is found in Attachment B of this letter. Type 2—Inland Fresh Meadows Inland fresh meadows(Type 2)wetlands have soil that is usually without standing water during most of the growing season but is waterlogged to within at least a few inches of its surface. Vegetation includes grasses,rushes,sedges,and various broad-leaved plants.In northern environments,typical species representatives are carex, rushes, redtop, reedgrasses, mannagrasses, prairie cordgrass and mints. Meadows may be present in shallow lake basins, sloughs, farmland "sags" or may border shallow marshes on the landward side. Table 4(Cowardin et al p.28)includes within its description of Type 2 wetlands as fen and northern sedge meadow. The water regime is described as saturated (B). This description, as used by some plant ecologists and wetland scientists,is specifically limiting and at least in some instances does not suggest that reed canary grass dominated wetlands would fall into this category. Type 3—Inland Shallow Fresh Marshes Inland shallow fresh marshes (Type 3) wetlands have a soil substrate that is usually waterlogged during the growing season and at some times may be covered with as much as 6 inches or more of water. Common vegetation includes grasses,bulrushes, spikerushes,and various other marsh plants such as cattails, arrowheads,pickerelweed, and smartweeds. Common representatives in the North include reed,whitetop,rice cutgrass,carex and giant burreed.Type 3 marshes may nearly fill shallow lake basins or sloughs or may border deep marshes on the landward side. They may also occur as seep areas in agricultural fields resulting from failing drain tile systems or where sand seams are near the surface on hillside slopes. Cowardin et al (Table 4, pg 28) describes the water regime as either seasonally flooded (C) or semipermanently flooded (F). The accurate categorization of Type 3 wetlands is most critical since seasonally flooded wetlands containing reed canary grass are eligible for larger de minimus fills(up to 10,000 square feet) than cattail marshes (only 400 square feet).