Don't get caught with an expired environmental permit.

In this time of renewed energy for restarting development projects that may have been halted or delayed during the economic slowdown, it has become increasingly important to know where your project stands in relation to previously obtained environmental permits.  Regulators also have seen a decrease in workload with the drop in incoming applications and many have used this time to review and modify existing guidelines and procedures.  In addition, several federal permit regulations have recently been renewed or are up for renewal in the near future.  In recent years the U.S. Army Corps of Engineers (Corps) has issued several regional manuals for wetland delineations, modifying the procedures and sometimes the results of delineations.  There is also evidence of increased pressure from regulatory review agencies such as the U.S. Fish and Wildlife Service to require applicants to complete threatened or endangered species and habitat surveys that may not have been required in the past. 

All of these recent changes could have an impact on the renewal process of previously issued wetlands delineation confirmations and Corps or Department of Environmental Quality issued permits. The best way to avoid many of these costly complications is to request a permit or confirmation extension prior to the expiration of the old one.  The regulatory agencies typically require notice one month before the expiration of the existing approval and the approval can generally be issued with minimal rereview of the project. 

Requesting the reapproval of a permit or delineation after the expiration date can result in a more in-depth review of the project.  In the case of a delineation confirmation, this can mean additional work to convert the site data to meet the current procedures and a second field review that could result in modifications to the wetland boundary.  In the case of a permit reapproval, this can mean a secondary review by outside agencies resulting in requests for costly site surveys and additional work to revise the application to meet current guidelines, not to mention additional permit fees.

Please feel free to contact us if you have any questions or concerns regarding current or expired environmental approvals.  We will be happy to assist you in any way that we can.