Section A - Ohio Department of Transportation

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Ecological
Wetlands
Streams & Rivers
Other Surface Waters
Terrestrial Habitat
Threatened & Endangered Species
Agency Coordination
Categorical Exclusion Training Class
Ecological Process
Project Initiation Package
Field Review
Present/Impacted
Ecological
Survey Report
ODOT Review
Agency
Coordination
Not present
NEPA
Document
Categorical Exclusion Training Class
2
Overview
o
o
Project Initiation Package
Ecological Survey Reports
 Level I - Projects that meet the MOA
 Minor Impacts (NWP)
 Projects that involve stream crossings, bank
stabilization, and/or minor wetland fills
 Level II – Projects with multiple alternatives
 Will require an individual 404/401 permit and/or
a Level 3 Isolated Wetland Permit
 Level III - Projects with multiple corridors
Categorical Exclusion Training Class
3
o
Overview
Agency Coordination
 Level 1 ESR
 ODNR
 USFWS
 Level 2 & 3 ESRs
 ODNR
 USFWS
 USACE
 OEPA
 EA/EIS
 USEPA
Special coordination may occur with NPS and ODNR
Scenic Rivers for any level of project.
Categorical Exclusion Training Class
4
Wetlands
Categorical Exclusion Training Class
Types
o
Adjacent or Abutting Wetlands (Non-Isolated)
 Hydrologic Connection
 OEPA Category (1, 2 or 3)
o
Isolated Wetlands
 No Hydrologic Connection
 Regulated by OEPA
 OEPA Category (1, 2 or 3)
Categorical Exclusion Training Class
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Online CE – Ecological Tab
Wetlands
o
Answer drop-downs appropriately
o
If wetlands are impacted, a table is generated
Categorical Exclusion Training Class
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o
o
o
o
o
Remarks
Identify who completed literature and field reviews
 Include date of when each was completed
Identify each wetland by name or ID identified
during field investigations
 If impacted, list accordingly in the table
Discuss the functions and values of each wetland
including ORAM scores
List the work that is occurring in each wetland and
associated impacts
 List commitments in a table that can be generated
in the Agency Coordination section
Discuss wetland finding and analysis
Categorical Exclusion Training Class
8
Example
The ecological survey was conducted by Mannik and Smith biologists on August 15-16, 2011. A Level 2 ESR
was submitted to ODOT on December 10, 2011.
The proposed project will substantially rehabilitate the existing I-70 bridges over the Stillwater River. In
order to accommodate the widened bridge deck, the proposed rehabilitation will include widening of the in
stream piers. A temporary causeway and coffer dams/cribs/sheeting will be required to allow for construction
access, including pier reconstruction.
Six emergent wetlands are present on gravel bars within the stream and below the ordinary high water mark.
These gravel bars will be impacted in whole or in part by the temporary causeway and widened piers. The
installation and removal of the temporary causeway is expected to eliminate these wetlands. However, it is
anticipated that wetland areas will redevelop as sediments are re-deposited following completion of the
project.
Avoidance methods were considered. Eliminating the main line improvements proposed under this project
(the "No Build" alternative) will not meet the identified needs of the project to maintain adequate pavement
condition, address conditions contributing the high accident rate, or provide adequate maintenance-of-traffic.
The No Build alternative was dismissed from consideration as it does not meet the purpose and need of the
project. Rehabilitation of these bridges without a temporary causeway would require full closure of each
bridge during construction. Maintaining at least two lanes of traffic on the interstate, which is considered
vital to national security, precludes closure of the bridges. Therefore rehabilitation as an avoidance measure is
not prudent. Any necessary wetland mitigation will be addressed as part of the waterway permit process.
Categorical Exclusion Training Class
9
Programmatic Wetland Finding
Agreement between FHWA and ODOT
o
Must include:
 Do Nothing (No Build)
 Improvements that will not result in wetland
impacts
 Measures to minimize and mitigate wetland
impacts
Categorical Exclusion Training Class
10
Programmatic Wetland Finding
o
Do Nothing Alternative
 One or more of the following must be documented:
 Would not correct existing or projected capacity
deficiencies
 Would not correct safety hazards
 Would not correct existing deteriorated
conditions and maintenance problems
 Would result in serious impacts to public
o
Addressed in Purpose & Need
Categorical Exclusion Training Class
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Programmatic Wetland Finding
o
Improvements that will not result in impacts are not
practicable because such avoidance would:
 Substantial adverse community impacts
 Substantially increases project cost
 Unique engineering, traffic, maintenance, or safety
issues
 Substantial adverse social, economic, or
environmental impacts
 Would not meet identified needs
Categorical Exclusion Training Class
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Programmatic Wetland Finding
o
Discuss ways wetland impacts can be avoided
 Retaining walls
 Alignment shifts
 Narrowed roadway
 Design exceptions
Categorical Exclusion Training Class
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Streams
&
Rivers
Categorical Exclusion Training Class
Types
o
National Scenic Rivers
 National Park Service (NPS)
o
State Wild, Scenic or Recreational Rivers
 Ohio Department Natural Resources (ODNR)
o
Navigable Rivers
 U.S. Coast Guard (USCG) Section 9 (Commercial)
 U.S. Army Corps of Engineers (USACE) Section 10
(Commercial & Recreational)
Categorical Exclusion Training Class
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Online CE – Ecological Tab
Streams & Rivers
o
Answer drop-downs appropriately
o
If impacts will occur, a table is generated
Categorical Exclusion Training Class
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Online CE – Ecological Tab
Streams & Rivers
o
In the table:
 List name or “use designation”
 No designation - list the QHEI or HHEI score
 QHEI
 Streams larger than 1 square mile drainage
 HHEI
 Streams smaller than 1 square mile
 Refresh Sums button calculates total impacts
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Remarks
o
Identify who completed literature/field reviews and
when they were completed
o
Identify each waterway by name/identification
 If impacted, list accordingly in the table
o
Discuss each waterway’s features, function, and
values
o
For National Scenic Rivers identify and discuss the
NPS Outstanding Remarkable Values
Categorical Exclusion Training Class
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o
o
o
o
o
Remarks
List type of activity occurring in each waterway
List amount of impacts to each resource
For projects with multiple waterways provide
information in matrix format
If waterways present, but no in-water work will
occur, state measures to be used to prevent possible
secondary impacts
List measures to avoid, minimize, or mitigate
impacts
 List commitments in a table that can be generated
in the Agency Coordination section
Categorical Exclusion Training Class
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Example
The ecological survey was conducted by Mannik and Smith biologists on August 15-16, 2011. A
Level 2 ESR was submitted to ODOT on December 10, 2011.
The proposed project will substantially rehabilitate the existing I-70 bridges over the Stillwater
River. In order to accommodate the widened bridge deck, the proposed rehabilitation will
include widening of the in-stream piers. A temporary causeway and coffer dams/cribs/sheeting
will be required to allow for construction access, including pier reconstruction. Any necessary
stream mitigation will be addressed as part of the waterway permit process.
The Stillwater River is a State-designated scenic river. ODOT, ODNR Scenic Rivers and the
design team conducted a field review on 03-21-2011. As the project can not avoid in-stream work
(both temporary and permanent), ODOT acknowledges that some form of mitigation for
involvement with the Stillwater is appropriate. Various options were discussed, including tree
plantings or honeysuckle removal within Englewood's Grossnickle Park or reconstruction of the
Englewood Reserve Bikeway to provide a more natural feature than the current gabion wall. The
project team will continue to work with ODNR Scenic Rivers to identify an acceptable
mitigation. BMPs as outlined in the most recent version of the ODOT CMS and SS 832 will be
followed to minimize siltation impacts during construction.
Categorical Exclusion Training Class
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Other
Surface Waters
Categorical Exclusion Training Class
o
o
o
o
o
o
Types
Reservoirs
Lakes
Farm Ponds
Detention Basins
Storm Water Management
Jurisdictional Ditches
Categorical Exclusion Training Class
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Online CE – Ecological Tab
Other Surface Waters
o
Answer drop-downs appropriately
 If impacts will occur, a table is not generated
Categorical Exclusion Training Class
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o
o
o
o
o
Remarks
Identify who completed literature and field reviews
and when they were completed
Identify each surface water by name or identification
number
Briefly discuss features, function, and values
List impacts to each surface water
List measures to avoid, minimize, and mitigate
impacts
 List commitments in a table that can be generated
in the Agency Coordination section
Categorical Exclusion Training Class
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Terrestrial
Habitat
Categorical Exclusion Training Class
Types
o
o
o
o
o
o
Mowed/disturbed habitat (roadside, lawns, etc.)
Agricultural (row-cropped and pasture)
Old-field/scrub-shrub
Forested (riparian/upland)
Remnant Prairie
Unique or High Quality
 Mature Climax Forest
 Remnant Prairies
 Any area with a prevalence of rare species
Categorical Exclusion Training Class
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Ecological Tab – Online CE
Terrestrial Habitat
o
Answer drop-downs and check boxes as appropriate
 If Unique or High Quality Habitat present,
checklist is generated (no table)
Categorical Exclusion Training Class
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o
o
o
o
Remarks
Identify who completed literature and field reviews
and when they were completed
Briefly discuss type of habitat identified
List impacts
List measures to avoid, minimize, and mitigate
impacts
 List commitments, as appropriate, in a table that
can be generated in the Agency Coordination
section
Categorical Exclusion Training Class
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Example
The project area consisted mostly of developed land (including developed open space,
developed low intensity, medium intensity and high intensity), which included the
maintained road right-of-way and adjacent less maintained areas just outside of the rightof-way. These areas were dominated by common upland herbaceous species and young
trees and shrubs. Approximately 124 acres of developed areas will be impacted.
A small amount of floodplain forest is present within the project area. This area is
dominated by typical riparian trees and shrubs. This narrow strip of riparian woodland is
located along the Stillwater River. Approximately 2.5 acres of floodplain forest will be
impacted.
As discussed in the wetland section of the CE, a small amount of emergent riverine (gravel
bar wetlands) will be impacted by the bridge work associated with the Stillwater River.
These wetlands were dominated by water willow (Justisica americana). Approximately
0.098 acre of wetlands will be impacted by this project.
No unique or high quality terrestrial habitats were found within the project area. All of
the habitats are common adjacent to the project area, and throughout Ohio. This project
will not cause significant local declines in these common habitats or the plant and animal
species found in these areas.
Categorical Exclusion Training Class
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Threatened
&
Endangered
Species
Categorical Exclusion Training Class
Ecological Tab - Online CE
o
Answer drop-downs appropriately
Indiana Bat
Categorical Exclusion Training Class
Snuffbox Mussel
31
Remarks
o
Federally Listed Species
 Identify all listed species and listing status known
from the county/counties where the project occurs
 Potential habitat present within the project area
and potential impacts to such habitat
 List known critical habitat
Kirtland Warbler
American Burying Beetle
Categorical Exclusion Training Class
Indiana Bat
32
Remarks
o
State Listed Species
 Identify all listed species and listing status known
within a mile of the project
 Discuss impacts to species and their suitable habitat
o
For both state and federal species, list efforts to avoid,
minimize, and mitigate impacts to listed species and
suitable habitat
 List commitments, as appropriate, in a table that can
be generated in the Agency Coordination section
Categorical Exclusion Training Class
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Example
The proposed project is located within the known habitat ranges of
the Indiana bat, rayed bean mussel and snuffbox mussel (all
federally-listed species of concern), the eastern massasauga
rattlesnake (federally-listed candidate species) and the bald eagle
(federally-listed species of concern).
Review of the ODNR Biodiversity Database identified one records of
the snuffbox mussel in the Stillwater River, approximately 1/4-mile
north of the project. A mussel survey undertaken for the project in
August 2011 identified the elktoe mussel, creek heelsplitter,
kidneyshell, and wavy-rayed lamp mussel (all State-listed species of
concern).
Categorical Exclusion Training Class
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Example
ODOT OES made the following effect determinations for federally-listed species:
Indiana bat: Based on the Level 2 ESR, two suitable roost trees and one suitable maternity roost may be
removed for this project. The project is connected to over 1000 acres of woods along the Stillwater River and
its tributary. Because cutting restrictions will be followed, no direct take of the Indiana bat is expected. The
potential loss of the maternity roost trees and necessary relocation of an Indiana bats using the tree could
cause additional stress to pregnant females and reduced survivability of the females and their young. The
proposed action "may affect and is likely to adversely affect" the Indiana bat. Conservation measure 6-a
(ODOT funded Indiana Bat research in the Big Darby drainage) was used to mitigate the unavoidable impacts
to this species’ habitat.
Snuffbox and Rayed Bean mussels: The snuffbox was historically known from this project area, and the rayed
bean is known from the Stillwater River in Montgomery County. Suitable habitats for these species are found
in the Stillwater River; however, no evidence of the rayed bean or snuffbox were found during the August 27
and 28th, 2011 mussel survey conducted by Dr. Michael Hoggarth (federally permitted malacologist). The
project "may affect but is not likely to adversely affect" these species.
Eastern massasauga: The project area consists primarily of mowed right-of-way. The wetlands located in the
project area are below the OHWM of the stream and do not offer habitat for this species. No wetlands located
adjacent to the project area offer habitat for this species. The project will have no effect on this species.
Bald eagle: The nearest bald eagle nesting activity is over 7 miles from the project. As no nesting activity has
been noted within 0.5-mile of the project area, this project will have no effect on this species.
Categorical Exclusion Training Class
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Example
ODOT-OES made the following effect determinations for state listed species:
A record for the snuffbox was found within the project area, but this species was not
found during the 2011 mussel survey. Habitat for this species was found to be
present within the project area. This project is not likely to impact this species.
The elktoe mussel (Alasmidonta marginata, SC), creek heelsplitter (Lasmigona
compressa, SC), kidneyshell (Ptycobranchus fasciolaris, SC), and wavy-rayed lamp
mussel (Lampsilis fasciola, SC) were found within the project area during the August
2011 mussel survey. All mussels will be relocated by a professional malacologist
within six months of construction, and the relocation will follow all applicable state
and federal survey protocols. As these species will be moved out of the impact zone
of the project, this project is not likely to impact these species. The post-relocation
survivability survey will be conducted 2 years after the relocation to determine the
relative success of the relocation, if ODNR and USFWS requests the survey.
Categorical Exclusion Training Class
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Agency
Coordination
Categorical Exclusion Training Class
Coordinating Agencies
o
Coordination efforts may potentially include:
 ODNR
 USFWS
 USACE
 OEPA
 ODNR-Scenic Rivers
 NPS-Scenic Rivers
Categorical Exclusion Training Class
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Ecological Tab – Online CE
Agency Coordination
o
Answer drop-downs appropriately
Categorical Exclusion Training Class
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Remarks
o
o
o
List all coordination dates
Document agency comments (commitments)
Document coordination between agencies and
ODOT on any dispute resolution
Example:
On 01-10-2012, ODOT coordinated the Level 2 Ecological Survey Report with USFWS,
ODNR, USACOE, and OEPA.
USACE Coordination: In response to the project notification, USACOE conducted a
joint field review with ODOT on 04-18-2012. USACOE noted that the in stream
vegetated sand/gravel bars should be delineated as wetlands. No other comments or
objections to the project have been received from USACOE. A request for a
jurisdictional determination has been made to USACOE; a determination has not yet
been received.
Categorical Exclusion Training Class
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Example
OEPA Coordination: On 01-24-2012, in response to the project notification, the OEPA noted that
an individual 401 Water Quality Certification may be required and stated that an official
decision regarding the 401 Water Quality Certification could not be provided until the
jurisdictional determination and regulatory documentation are received. The OEPA did not
object to the project.
USFWS Coordination: ODOT informed USFWS of its effect determinations for federally-listed
species. On 05-21-2012, USFWS concurred with the effect determinations for the Indiana bat,
rayed bean mussel, and snuffbox mussel. USFWS noted, and did not object to, the "no effect"
determinations for the eastern massasauga and bald eagle.
The USFWS issued, via the 05-21-2012 letter, a Programmatic Tier 1 Biological Opinion for the
Indiana bat. USFWS concluded that the project is likely to adversely affect the Indiana bat, but
is not likely to jeopardize the Indiana bat. The incidental take for this project is estimated at 1.0
acre and has been added to the cumulative total of incidental take for ODOT's Statewide
Transportation Program. The project will be subject to the tree cutting restriction from April 1
to September 30 (Programmatic Biological Opinion conservation measure A-1). Further ODOT
will apply credits from the Big Darby Creek Research Bank to this project (Programmatic
Biological Opinion conservation measure M-6a).
Categorical Exclusion Training Class
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Example
ODNR Coordination: In its inter-office memo to ODNR, ODOT provided details regarding the mussel
survey undertaken in August 2011 and informed ODNR that a mussel relocation will be undertaken
within six months prior to construction.
On 02-16-2012, ODNR provided comments and
recommendations.
ODNR Division of Wildlife requested in-stream restriction dates; as these dates are less restrictive
than those requested by ODNR Scenic Rivers, they will not be utilized. As requested by ODNR
Division of Fish & Wildlife, the mussel survey and relocation reports will be provided to ODNR when
available.
ODNR Scenic Rivers has provided specific recommendations for protection of the scenic Stillwater
River. These recommendations will be incorporated into the project design or addressed through plan
notes, as appropriate (see environmental commitments). As noted under "Streams & Rivers" above,
ODOT is currently working with ODNR Scenic Rivers to identify appropriate mitigation measures for
the necessary in stream work within the scenic Stillwater River.
ODNR Division of Soil & Water inquired if there would be impacts to other streams within the
corridor. Other than the bridges carrying I-70 over the Stillwater River, the project will not include in
stream work at any bridges or culverts within the corridor. ODNR DSW noted the presence of a
possible shallow marsh within the Stillwater River. As noted below, ODOT has requested a
jurisdictional determination from USACOE. ODNR DSW requested that ODOT mitigate for loss of
habitat through native plantings within the interchange and median. As ODOT has previously
informed ODNR, preservation of line of sight through regular mowing generally precludes the
successful use of native plantings.
Categorical Exclusion Training Class
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Environmental Commitments
o
Examples may include, but are not limited to:
 In-stream work restrictions
 Species surveys and/or relocations
 Cutting dates or avoiding terrestrial areas at certain times of
o
year (or other avoidance/minimization)
 Adhering to fill limits allowed by permit (permanent &
temporary fills)
 Monitoring of adjacent areas post-impact
Can be implemented by:
Plan notes
Design changes resulting in changes to plans
Special Provisions
Utilizing OES staff, consultants, or contractors (depending on
activity) to conduct commitment work prior to construction
 Conducting mitigation/conservation measures in some fashion




Categorical Exclusion Training Class
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Online CE Project File/Part of CE
o
Correspondence with Resource Agencies:
 Coordination Letters to Agencies
 Comments and/or Approval Letters
 Map illustrating location of ecological resources
 Jurisdictional Determination (JD) Letter
Categorical Exclusion Training Class
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Waterway
Permits
Categorical Exclusion Training Class
Waterway Permits
•
•
•
•
Waterway permitting starts at the district level.
The permit determination process involves coordination between the district and
OES-WPU (Waterway Permit Unit).
Ecosurvey report = quantity and quality of waterways.
Project constraints such as construction limits, right-of-way, design build = amount
and type of impacts.
Categorical Exclusion Training Class
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Waterway Permits
Permit Determination Process
•
A permit determination is the process OES-WPU uses to determine the level of
waterway permit required.
•
A permit determination request form is submitted to OES-WPU for review by the
district.
•
The district or a consultant can complete the form.
•
OES-WPU evaluates the impacts and responds with a permit determination IOC
(PDIOC).
•
Typically, OES-WPU only reviews permit determination requests for ODOT-let
projects (including ODOT-let LPA and maintenance).
•
Local-let projects may also use this process. OES-WPU may or may not assist the
locals in the permit determination process.
Categorical Exclusion Training Class
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Waterway Permits
Online CE and Waterway Permits
•
•
If there are no waterway impacts, no permits are required, check “no”.
If there are waterway impacts, a permit determination must be completed before
answering this question.
– If a permit determination has NOT been completed, DO NOT GUESS. Leave blank
and explain in the remarks the status of the permit determination.
– If a permit determination has been completed, answer according to the permit
determination.
Categorical Exclusion Training Class
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Waterway Permits
Permit Determination
Request Form
• First step in making a permit
determination.
• Requires information from
the ecosurvey report, plan
sheets, and other project
details.
• 2-page instructions are
available.
• OES-WPU responds to the
district via a one-page letter
(PDIOC).
Categorical Exclusion Training Class
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Waterway Permits
PDIOC 
• OES-WPU response to the district
• Identifies the level of permit, or if
agency coordination is required:
– For example, coverage under
the Regional General Permit or
Nationwide Permit,
– Or if a Pre-Construction
Notification (PCN) or other
permit submittal is necessary
• Identifies mitigation needs
• Reminds the district of permit
expiration dates, in water work
restrictions, or pre-application
meetings
Categorical Exclusion Training Class
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Waterway Permits
• Once a permit
determination has been
completed and a PDIOC
is sent back to the
district, information can
be added to the CE
online.
• Reminder, once you
have populated a field,
you cannot return to a
blank field.
Categorical Exclusion Training Class
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Waterway Permits
• In the Remarks Section of the CE Online, discuss
the findings of the Permit Determination.
– Is the project covered under the Regional General
Permit or Nationwide Permit?
– Will waterway permit application(s) need to be
submitted to the agencies for authorization, for
example a 401 Water Quality Certification and/or 404
Individual permit?
– Waterway Permits must be granted before waters can
be impacted, but the CE can be cleared prior to permit
authorization.
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Waterway Permits
• In the Environmental Commitments Section of the CE Online,
discuss the status of the Waterway Permits for the project.
• If not found in the ecological section, indicate any other
commitments such as a mussel survey, in-water work
restrictions, mitigation of waterway impacts, no build zones,
etc.
Categorical Exclusion Training Class
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Waterway Permits
• If Waterway Permits have been authorized, state
specifically which ones and cite the special provisions…
– For example, “Nationwide Permit #3 was authorized by the USACE for this
project. Specific conditions of the permit are found in the Waterway Permit
Conditions, Special Provisions.”
• If waterway permits have NOT been authorized, indicate
which were applied for, when, and a statement that
waters will not be impacted until permits are granted and
special provisions have been completed.
– For example, “A USACE 404 Individual Permit and OEPA 401 Water Quality
Certification application were submitted in September 2014. No waters can
be impacted until these permits have been granted.”
Categorical Exclusion Training Class
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Waterway Permits
• Reminder, the (Waterway) Permits portion of the CE
can be cleared prior to a permit determination and
agency authorization and grant of permits IF the
Remarks and Environmental Commitments are
appropriate.
• Remarks indicate the progress of the permits.
• Environmental Commitments at a minimum must
state that “no waters will be impacted until a
401/404 permit has been obtained.”
Categorical Exclusion Training Class
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Permits
Floodplains
Categorical Exclusion Training Class
Floodplains Process
Project Initiation Package
Field Review
Not Present
Floodplain Administrator
Coordination
NEPA
Document
Categorical Exclusion Training Class
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Online CE – Permits Tab
Floodplains
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Remarks
 Describe impacts to floodplain, floodway, and base
flood elevations
 Coordination with Local Floodplain Administrator
 Can be an environmental commitment completed
during the design phase
Categorical Exclusion Training Class
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Example
According to Federal Emergency Management Agency’s (FEMA)
Flood Insurance Rate Map (FIRM) Panel No. 39153CO212E,
effective July 20, 2009, the proposed undertaking will impact the
100-year floodplain of both Haley’s Ditch and Springfield Lake
Outlet (Attachment E1a, page 102 presents a portion of this FEMA
panel and Attachment E1b, page 103 shows that no floodplains
occur in the proposed project area).
(Continued on page 8a)
Categorical Exclusion Training Class
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Example
Floodplains (continued):
The proposed undertaking will cross Haley’s Ditch and Springfield Lake Outlet with three-sided box Con-span
arch culverts. On the proposed project area portion of the FEMA panel, the floodplain of Haley’s Ditch has not
been updated since that channel was relocated and channelized in the late 1970s (Attachment E1a, page
102). The combined project impacts on the 100-year floodplains of both Haley’s Ditch and Springfield Lake
Outlet are proposed to be less than 0.3 acre.
Since the proposed undertaking is located within a floodplain regulated by FEMA, coordination with the local
floodplain administer is required. On December 22, 2010, floodplain coordination correspondence was sent to
the designated floodplain administrator at the City of Akron (see Attachment E2, pages 104-106 for a copy
of the correspondence).
See Attachment E3, pages 107-108 for a copy of the Akron Engineering Bureau correspondence, dated
March 21, 2011 for the project. This coordination letter states that the project will be required to comply with
all sections of the City of Akron code, Article 3 Flood Hazard Areas, Section 197.300 to 197.319 and meet or
exceed the minimum FEMA standards. Any encroachment within the floodway that would result in an increase
in the base flood elevation can only be granted upon approval by FEMA.
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Online CE Project File/Part of CE
 Floodplain Administrator Correspondence and/or
Coordination
 FEMA Flood Insurance Rate Maps (FIRM)
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FEMA Map
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