PARTNER CENTRAL - ENVIRONMENTAL
General Authorization (GA) / Regional General Permit (RGP)
What are the GA and RGP?
The General Authorization (GA) issued by Oregon Department of State Lands (ODSL) and the Regional General Permit (RGP) issued by the Army Corps of Engineers (Corps) are authorizations for activities that affect wetlands and waters of the state and / or U.S. (i.e., rivers, streams, etc.).
General Authorization (GA) for Removal / Fill - Oregon's Removal / Fill Law allows the Oregon Department of State Lands (ODSL) to grant, by administrative rule, GAs for removal and fill activities that would cause only minimal individual and cumulative environmental impacts, and would not result in long-term harm to water resources of the state. The GA for Certain Transportation-Related Structures covers all ODOT bridge repair and replacement projects that meet the terms and conditions of the GA, not just OTIA III funded bridge projects.
Regional General Permit (RGP) - This permit is granted by the U.S. Army Corps of Engineers (Corps) to ODOT to cover proposed bridge repair and replacement activities under the OTIA III program. The RGP was issued pursuant to the Corps’ authority under the Clean Water Act. It includes conditions for certification pursuant to Section 401 of the Clean Water Act and the Coastal Zone Management Act (CZMA).
NOTE RGP applies only to projects that are part of the OTIA III bridge program.
How do I know if GA / RGP authorizations are needed for a bridge site?
GA / RGP authorization(s) are needed for any removal / fill activities that affect wetlands or waters of the U. S. (RGP) or state (GA).
All wetlands potentially affected by activities at a given site must be delineated. If wetlands are present but not delineated, additional assessment work will be required. In addition, to meet GA/RGP requirements for the OTIA III program, all activities potentially affecting wetlands must demonstrate compliance with performance standards and identify of appropriate mitigation strategies.
As part of the statewide bridge assessment effort, data on wetlands were gathered from three sources:
- USFWS National Wetlands Inventory (NWI). This nationwide survey uses aerial photography to examine vegetation types, changes in vegetation, and other factors to indicate the presence of wetlands.
- SR-SAM. ODOT's Salmon Resources and Sensitive Area Mapping (SR-SAM) project was developed to enable road maintenance crews to perform their duties (mowing, pesticide application, etc.) with minimal disturbance to sensitive resource areas. This project maps resource data along the state's transportation corridors using a combination of Global Positioning System (GPS) and digital imaging technologies. SR-SAM wetlands data are generally more precise than NWI data.
- Field crews performed onsite surveys of potential wetland areas associated with bridge sites in the OTIA III program. Depending on access restrictions, field crews were able to provide even more complete and accurate wetlands information.
- When full access was not possible (no right of entry, rough terrain, etc.), field crews performed wetlands determinations based on visual observations of vegetation, NRCS soil mapping, and hydrology indicators.
- When sites were accessible, field crews performed full wetland delineations. This included identifying vegetation species and hydrology, mapping wetland boundaries using GPS, and digging soil pits to determine soil characteristics. Reports were not always prepared for this effort.
Who is responsible for verifying wetlands delineations?
For a preliminary determination of the presence of wetlands and / or waters of the U. S. or state, refer to Section 3.12, Wetlands in the environmental baseline report for the subject bridge and to the ODOT Bridges TransGIS.
ODSL grants final approval of wetlands delineations. Individual contractors are responsible for ensuring ODSL concurrence of wetlands delineations – concurrence was not obtained during the environmental baseline report effort.
How do I determine appropriate removal/fill activities and limits for a particular site?
Determination of removal/fill activities and limits for a particular site must be done in consultation with Oregon Bridge Delivery Partners (OBDP).
- Be sure that you are familiar with the Corps' Regional General Permit and with ODSL's General Authorization for Removal / Fill. Read both of these authorizations carefully before proceeding with any design or construction activities.
- For the Corps, limits are no more than 1.0 acre of total fill, and no more than 0.5 acre of permanent fill, per single and complete project. If two bridge structures cross the same feature in the same location (i.e., divided highways with separate structures for each direction of traffic), and if these two structures are being repaired or replaced at the same time, the two structures are considered as a single project by the COE.
- For ODSL, OAR 141-089-0555 states that "Permanent fill in [a] wetland is limited to 0.5 acre or less. In waters other than wetlands, no more than a total of five thousand (5,000) cubic yards of material may be filled, removed or altered in waters of the state for a single and complete project. Exceeding five thousand (5,000) cubic yards is authorized only where necessary to improve or restore fluvial processes on a project specific basis." See Department of State Lands, General Authorizations, Division 141-089: General Authorization for Certain Transportation-Related Structures (page 13).
- Develop a Preconstruction Assessment (PCA) demonstrating compliance with the OTIA III bridge program performance standards, consulting OBDP as needed, and submit the PCA to OBDP for review. OBDP will review the PCA, working with the contractor as needed. When OBDP has approved the PCA, OBDP will work with the contractor to transmit it to the appropriate agencies for their review and approval. Note that PCA approval by OBDP does NOT constitute agency approval to proceed or issuance of any permits. OBDP will notify the contractor when the agencies have issued their permits or authorizations to proceed.
- Consult with OBDP to determine appropriate removal/fill limits for a particular bridge site. Note that removal/fill limits are specified in the GA and RGP, as described above; the individual contractor must assess their compliance. Use the wetlands and waterways removal / fill calculation template to document impacts for the PCA.
How do I use the GA / RGP?
Successful completion and acceptance by OBDP and ODOT of the Pre-Construction Assessment will enable contractors to meet wetlands permitting requirements through the GA / RGP.