Wetland Delineation Is More Than Flagging

For small, undisturbed residential lots, wetland flagging alone may be sufficient to support limited permitting needs. However, for larger or more complex projects—such as subdivisions, commercial development, municipal work, or sites with a history of grading or fill—regulators increasingly expect more than just boundary flags on a plan.

New Hampshire Department of Environmental Services (NHDES) administrative rules make this distinction clear. Under Env-Wt 311.05(b), plans depicting wetland boundaries submitted with a standard permit application must meet specific documentation requirements, as cited:

Env-Wt 311.05(b):Plans depicting wetland boundaries that are submitted with an application for a standard permit shall: (1) Show the location and number of the individual wetland boundary flags or other markings, as located by survey or by GPS;(2) If prepared by a certified wetland scientist, be stamped by the certified wetland scientist who prepared the plan(s) or who oversaw the wetland boundary delineation if done by an apprentice or an associate who is not a certified wetland scientist;(3) If not prepared by a certified wetland scientist, be accompanied by a report that includes an existing conditions plan that has been prepared and stamped by a certified wetland scientist;(4) If prepared by a homeowner acting on his or her own behalf for the development of the homeowner’s primary residence, be signed by the homeowner in accordance with Env-Wt 311.11;(5) Include notes that specify:    a. The date(s) on which the wetlands delineation was performed; and    b. The method of delineation; and(6) Be accompanied by:    a. A report of existing conditions, if the jurisdictional areas have not been disturbed; or    b. US Army Corps of Engineers data sheets, if disturbed conditions exist.

This rule directly links the level of documentation required to the condition of the site.

Why Disturbed Sites Require More Documentation

On sites that have been significantly disturbed—through past grading, filling, logging, agricultural use, or construction—wetland indicators are often altered, obscured, or incomplete. In these situations, NHDES requires the use of U.S. Army Corps of Engineers (USACE) data sheets to document soils, vegetation, and hydrology in a standardized and defensible way.

These data sheets are not optional when disturbed conditions exist; they are the required method for demonstrating wetland jurisdiction and supporting permit review under both state and federal frameworks.

A Wetland Descriptions Report provides the structure needed to:

• Document existing conditions clearly

• Explain how wetland boundaries were determined

• Identify wetland types and classifications

• Support the use of USACE data sheets where required

• Reduce questions, delays, and requests for additional information during review

Why Ecosystems Is Making This the Standard

For projects beyond simple single-lot residential development, a Wetland Descriptions Report:

• Aligns with Env-Wt 311.05(b) requirements

• Anticipates regulatory expectations early

• Improves coordination with engineers, planners, and surveyors

• Reduces the risk of redesign or resubmittal later in the process

• Provides clearer documentation for land-planning and permitting decisions

By incorporating this report as a standard deliverable for more complex projects, we help our clients move through permitting with fewer surprises and stronger documentation.

A Practical, Proactive Approach

This added step reflects a proactive approach to wetland consulting—one that recognizes that early, clear documentation is often the most efficient path through permitting and project design.

As always, Ecosystems Land Planning tailors the level of effort to the scale and complexity of the project, and we are happy to discuss whether a Wetland Descriptions Report is appropriate for your specific site.