On November 16, ECOS submitted a letter to the Federal Register in response to the U.S. Army Corps of Engineers (USACE) Proposal To Reissue and Modify Nationwide Permits (NWP). The letter acknowledges that NWPs are regulatory tools that can streamline permitting processes while also incorporating conditions that mitigate negative environmental impacts. It also asks USACE to make allowances for the challenges created for states by the timing of the proposal, reconsider the waiving or changing of some Pre-construction Notification (PCN) requirements, ensure that state conditions included in Clean Water Act (CWA) Section 401 certifications are enforceable, and keep the 300 linear foot limit for the loss of streambed to better protect small streams.
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