NORTON ENGINEERING

	Norton Engineering LLC "Engineering a Better World" (937) 223-5848
		Consultants in Dayton, Ohio

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401 and 404 Permitting
for Religious Institution in Dayton, OH

The Christian Life Church plans to add another large campus building on their property. It is to be built to the west, in front, of their existing building with corridors connecting the two. The space between the two buildings enclosed by the new corridors will be a lovely green lawn space available for social gatherings.

DRAINAGE DITCH DURING
WINTER SNOW MELT

This rather straight forward project had a complication, however. Across the location of the proposed new enclosed green space is a storm drainage ditch. This ditch was constructed across the church property when Interstate -70 was built to provide drainage for highway runoff and direct it towards the Stillwater River. A culvert can be installed in the place of this ditch to carry the stormwater under the green space and corridors, but not without getting approval from the US Army Corps of Engineers ("USACE") and the Ohio EPA, which view this ditch as an "upland stream habitat."

Because the stormwater eventually discharges to the Stillwater River, the ditch is considered a federally regulated body of water and requires a 404 permit from the Army Corps of Engineers to close it in with a culvert. Applying for a 404 Nationwide Permit can be quite onerous. There are forms to be filled out with drawings and data that needs to be assembled. There are dozens of types of General Permits that can be secured if a project seems to meet their specific criteria. This church project appeared to meet the criteria for one of the general permits because it was under 300 feet long. However...

UPLAND WATER SOURCE:
HIGHWAY RUNOFF

Further complicating matters was the disparity in culvert length allowance between the Federal and Ohio State permitting agencies. The US Army Corps of Engineers allows 300 feet of new culvert on their jurisdictional waters, but the Ohio EPA only allows 200 feet. This church project needed to close in 236 feet between two existing culverts on this ditch. Leaving a 36 foot hole in the interior lawn just didn't make sense. This Church expansion project needed an "individual project water quality certification" with public notifications and possibly public hearings as outlined under Section 401 of the Clean Water Act.

These new requirements have already delayed construction several months, and may delay the project until the next construction season. This is particularly unfortunate during an economic downturn when every job is so important.

401 and 404 Permitting for Religious Institution in Dayton, OH

401 and 404 Permitting
for Religious Institution in Dayton, OH