There are many, many permits issued to fill and/or dredge wetlands in the New Orleans District, perhaps the most vulnerable district to wetland destruction in the United States. And many project reviewers. There may be 30 standard permits a week, and few advocates, whose time is overcommitted. There are probably more general permits issued—these are never publicly noticed. It takes a watchdog a minimum of 4 hours to review the 404 website for possible targets for comment, and 8 hours average for each comment. Each FOIA takes an hour minimum. Phone calls with regulators take 15 minutes to half an hour, usually.

Once permits "fall off the page," a FOIA must be submitted to obtain documents that were once public. Final Decision documents almost always require a FOIA. It would be more productive to have to mail one FOIA.

Automated scrape would preserve these documents, and allow yearly review of impacts allowed by permitting. It would free up advocate time to investigate general permits hidden from public view, as well as follow up on decision documents and investigate permit violations—all of which are needed for effective watchdogging. It would assist independent review of cumulative impacts, as required of the Army Corps by rule.

Additional services like OCR and text searches within the Public Notice could streamline permit review even more. The Mississippi river Collaborative has recently proposed commenting on all permits 10 acres or more. In the New Orleans District, this will increase the work load substantially. Any time saved in permit review, finding these 10 acre permits, is time better spent fighting bad permits, and analyzing the patterns of Corps regulatory to strategically fight wetlands destruction.

Analysing and preventing wetlands destruction from the 404 process in the New Orleans District presents a challenge beyond that in most districts. But if this program is successful, it can be applied to other Army Corps Districts around the nation.

The Army Corps, by federal rule, is required to analyse permits for “Cumulative” impact of permitting, by using a “Watershed Approach.”

Holy Moly, but do they avoid doing this. They do know how, but need encouragement. Automation would assist them as well.

Such a recordkeeping / databasing/ spreadsheet-making scraper software would aid in our pressure for the Corps to regard cumulative impacts of Permits. It would also assist independent scientific review of impacts and mitigation.

Thanks for whatever assistance you can give to our efforts to protect the wetlands that protect us. Thanks for helping to keep us afloat.

For a Healthy Gulf,

Scott

A more detailed prospectus is in the prospectus directory. The program is in the directories v*; you should use the highest version.