US Army Corps of Engineers Recommends Pre-Application Consultation for Site Plans On September 29, 2004, the US Army Corps of Engineers (COE) issued a letter to the development and consulting community stating that they have noticed an escalating trend in prospective applicants who are unable or unwilling to share preliminary site plans with the COE at the time of pre-application review. Often times, the Corps notes, this ultimately causes difficulty in the long-run for applicants who find they have created site plans that fail to minimize impacts to environmentally sensitive areas to the fullest extent practicable. This can result in obtaining local zoning and/or plan approvals for a project that may not be permitable by the COE due to the extent of wetlands and stream impacts. Therefore, the COE is strongly encouraging developers to consider pre-application designs that take into account "the location of waters and wetlands and avoid and/or minimize impacts to them whenever and wherever practicable"; and to avail themselves of the pre-application consultation process before securing local approvals. DEQ appears to be acting in concert with the COE on this subject. Planners should expect pressure to avoid all impacts other than those needed for road and utility crossings, stormwater outfalls, minor fills, and impacts to degraded aquatic systems. Upland buffers (25'-50') around wetlands and streams (100' if perennial) will also be requested, as described in Nationwide Permit (NWP) Condition No. 19. Furthermore, the COE is also taking steps to contact localities so that they (the COE) can participate in the evaluation of generalized development plans and preliminary plans at the local level. Starting in November, on a preliminary basis in Northern Virginia, a COE representative will meet weekly with plan reviewers in Prince William County to ensure site plan designs avoid and minimize impacts to environmentally sensitive areas. This may be expanded to include more localities in the future. This is an attempt to convey concerns earlier in the process, rather than later – after plans have been locally approved and significant investments have been made. For further information, contact Dan Lucey, P.E.; Mark Headly, P.W.S.; or Mike Rolband, P.E., P.W.S.