ASFPM Comments comments regarding the Proposed Nationwide Permits (NWPs)

April 18, 2011

U.S. Army Corps of Engineers
Attn: CECW‐CO‐R
441 G Street, N.W.
Washington, DC 20314‐1000

RE: Docket # COE‐2010‐0035; ZRIN 0710‐ZA05

Submitted via email to NWP2012@usace.army.mil and Rulemaking Portal at www.regulations.gov.

Dear Mr. Olson:

The following comments to the Proposed Nationwide Permits are submitted on behalf of the Association of State Floodplain Managers (ASFPM), and more than 14,000 ASFPM members who are the Federal government’s partners in efforts to identify, stabilize, and reduce flood losses. We appreciate this opportunity to share with you our comments and suggestions regarding the Proposed Nationwide Permits (NWPs) and their potential impact on flood risk and associated loss of life, property, and floodplain natural resources. Through these comments, we wish to address the need for NWPs to assure coordination with existing Federal, State, and local floodplain management regulations as part of the Section 404 and Section 10 permitting processes. We also address potential floodplain impacts likely to result from the Proposed NWPs as they are currently drafted, and provide for your consideration our suggestions to lessen the likelihood of those impacts. The U.S. Army Corps of Engineers and ASFPM have enjoyed a successful partnership for many years. We appreciate this opportunity to provide these comments. Please feel free to contact us with any questions you may have regarding this comments, and any time we can be of assistance.

Sincerely,

Greg Main CFM Larry Larson, P.E., CFM

ASFPM Chair ASFPM Executive Director

CC: Lieutenant General Robert L. “Van” Van Antwerp, USACE Major General William Grisoli, USACE Jo‐Ellen Darcy, Assistant Secretary, Civil Works, ASA

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