Minor changes to minor permits
August 5th, 2010 by Dana WrightLast week TDEC finalized the changes to the general Aquatic Resource Alteration Permits (ARAPs). These ARAPs are for smaller, less impacing projects proposing to physically impact waters of the state and do not require mitigation. As is typical, TCWN submitted comments when the draft permits were put on public notice. We had some minor success in response to our comments. The overall problem with these general permits is their use on smaller aspects of large projects. For example, using a general permit for multiple small road crossing in a project impacting thousands of feet of stream covering several acres. The result can be hundreds of feet of stream lost without any mitigation.
Well, TDEC agreed “with the intent of not using the general permits in incremental means to allow larger alterations.” Additional language will be put in the general ARAP for road crossings so the permit is not used in such a way. A small step, but a very important one to prevent unmitigated, permanent loss of our important water resources. Click here to see TDEC’s response to all comments.


