The Vicksburg Corps of Engineers issues multiple nationwide permits 7 and 12 for the El Dorado waste water pipeline. The Corps' own rules prohibit multiple permits if more than 1/2 acre is needed for the project.
See the below analysis that proves these permits are not adequate for this project and should be revoked.
A project this large needs an Individual Permit with a public hearing. El Dorado Utilities was going in that direction when the Corps offered the lesser permits instead. E-Mails aquired with FOIA requests show that this was done to avoid the public hearing thereby dening the public their right to speak. These permits should be revocked and the proper permit applied for.

Beginning Note: This is portions of document; The Regulatory Program of the US Army Corps of Engineers describes Wetlands or “Waters of the United States” under U.S.C. 1344, 328.3 Definitiona as “Definitions” (3) All other waters such as interstate lakes, rivers, streams (including intermittent streams), mudflats, sandflats, wetlands, sloughs, prarie potholes, wet meadows, playa takes, or natural ponds, the use.(7) Wetlands adjacent to waters (other than waters that are themselves wetlands) identified in paragraphs (a) (1)-(6) of this section. Paragraph (8) (b) The term “wetlands” means those areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include Swamps, Marshes, Bogs, and similar areas.

This project is being permitted by the U.S. Army Corps of Engineers under their Special Conditions Nationwide Permit No.12 “Utility Lines” which according to paragraph 1 “provided the activity does not result in loss of greater than ½ acre of the Waters of the United States” yet the total area being required for mitigation is 16.62 acres as per “Table 2 Wetland Areas Requiring Mitigation”.

Nationwide permit (12) Utility Line Activities states “For the purpose of this NWP, the loss of waters of the United States (wetlands) includes the filled area plus waters of the United States (wetlands) that are adversely effected by flooding, excavation, or drainage as a result of the project. Activities authorized by paragraphs (i) through (iv) may not exceed a total of ½ acre loss of waters of the United States (wetlands).

In the Environmental Engineers report portion titled “Mitigation Plan for Ouachita Pipeline. El Dorado . Arkansas, Union County”, again no page numbers, in paragraph 1, Section (a) it states “A vegetation along a 50 ft wide right-of-way will be cleared during construction and the right-of-way will be maintained as an herbaceous layer”.

Nationwide Permit No. 12 Measures the loss of wetlands of only the trench of the project if the wetlands are restored to their pre-construction contours and elevations. This being the case the project is still over the ½ acre just using the 16.62 acres of mitigated property, for example:

Nowhere in the Environmental Engineering report or mitigation plan does it indicate what size the pipe will be. First, using 24 inch pipe as reported on television; 16.62 Acres of 50 ft. Right of Way calculates to 14,479.34 linear feet, The “Nationwide Permit No. 12” is calculated using only the diameter of the pipe or trench as the multiplying factor. A 2ft wide pipe or trench multiplied by the 14,479.34 feet of proposed Right of Way comes out to 0.665 Acres, OR one half acre of 24” pipe requires 10,890 linear feet, this pipeline is over the ½ acre by 3,589.34 linear feet of pipe. This is using just the pipe width, to excavate and install a 24 inch pipe it will take much more than an exact 24” trench but for our purposes to show that the pipeline does not qualify we will use the exact pipe widths.

A 30 inch pipe is shown on the Ouachita River Effluent Pipeline Diffuser Details drawn by GBMc Assoc. so again 16.62 Acres of 50ft. Right-of-way calculates to be 14,479.34 linear feet. 30 inch pipe would come out to 0.83 acres or 8,712 linear feet, this pipe line would then be 5,767.30 linear feet over ½ acre. Just in the 16.62 acres of mitigation.

The Environmental Engineering report shows in “Table 1 All Wetlands Areas Identified”, “28.99 Total Acreage”. According to the “Nationwide Permit No. 12” it only addresses Waters of the United States, (wetlands), it does not distinguish between “mitigated wetlands” it simply says Waters of the United States this means this project will have a trench cut through it 25,256.09 feet long. That would come out to 1.160 acres for a 24” pipe and 1.45 acres for a 30” pipe which is well over the permit maximum of ½ acres. Another factor that we cannot account for until we see the plans are Lift/Pump Stations. It is doubtful that all 28 miles of pipeline is gravity flow. If lift stations are being constructed the building slab areas must be counted as lost Waters of the united States.

Notes: There were public records requests sent to GBMc Associates requesting any plans and specifications regarding the Ouachita River / El Dorado Sewer Pipeline and GMBc Assoc. said none exists. In the mitigation paperwork are two sets of specifications with GBMc Assoc.'s Company Logo on them. These are not standard details, they are specifically for the Ouachita River / El Dorado Sewer Pipeline.

There are two areas of permanent Standing Water approximately 4,000 and 11,000 feet along the pipeline from the Ouachita River. Why aren't these included in the mitigation process?

There are two places delineated as PL-9-1 and PL-9-2 that test positive as wetlands that are not inluded in the mitigation plan. These points and their geographic coordinates are found on “Table 1” “Summery of wetland criteria met at each field verification site” I cannot give page numbers because the majority of the report, study and mitigation plan has no page numbers.