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City Council Memo - 5.6.2025Date: May 7, 2025 To: Chanhassen Mayor and Chanhassen City Council From: Eric Maass, AICP, EDFP Subject: Pioneer Ridge Development Land Disturbance and Tree Clearing Contract At the May 5th, 2025 City Council meeting the City Council was asked to consider a Land Disturbance and Tree Clearing Contract associated with the townhome development referred to as Pioneer Ridge. That contract would have allowed for tree removals following preliminary plat appro val but prior to final plat approval with certain conditions and financial securities. This contract was being considered under the basis of a deadline for tree removals of June 1 st, 2025 related to federal regulations regarding the northern long eared bat. Based on questions surrounding the extent of tree removals, the City Council did not take action on the proposed contract and directed staff to work with the applicant to provide clarifications to concerns related to the proposed tree removals. City of Chanhassen planning and forestry staff met with representatives from Brandl Anderson, including their ecological consultant, on May 6 th. After further review of the federal regulations pertaining to protection of the Northern Long-Eared Bat, it was found that the federal regulations only apply to a construction project when it has a federal nexus, such as a federal permit or federal fundi ng. The U.S. Army Corps of Engineers issued a letter dated April 14, 2025, indicating that the Pioneer Ridge project does not require a federal permit through their organization. Additionally, there is no federal funding associated with the Pioneer Ridge project. Based on no federal permit or funding, there is no federal nexus between the Pioneer Ridge project an d federal regulations. As a result, there are no timing restrictions for tree removals for the Pioneer Ridge development and the City Council will not be asked to consider a Land Disturbance and Tree Removal Contract at its meeting on May 12 th, 2025. Tree removals and grading of the site will commence only after the City has approved the final construction plans. Sincerely, Eric Maass, Community Development Director Attachments: Army Corps of Engineers Letter dated April 14, 2025. DEPARTMENT OF THE ARMY U.S. ARMY CORPS OF ENGINEERS, ST. PAUL DISTRICT ST. PAUL DISTRICT OFFICE 332 MINNESOTA STREET SUITE E1500 ST. PAUL MINNESOTA 55101 April 14, 2025 Regulatory File No. MVP-2025-00368-SSC Christopher Contreras Pioneer Ridge, LLC 221 River Ridge Circle South Burnsville, Minnesota 55337 ccontreras@brandlanderson.com Dear Christopher Contreras, This letter contains an Approved Jurisdictional Determination (AJD) for the area(s) identified below, located on the Brandl Anderson - Pioneer Ridge site in Section 27, Township 116N, Range 023W, Carver County, Minnesota. The review area for this determination is identified on the enclosed figure labeled: MVP-2025-00368-SSC, Pages 1-3 of 3. Non-Jurisdictional Area(s): We have determined that the following area(s) are not waters of the United States subject to Corps of Engineers (Corps) jurisdiction under Section 404 of the Clean Water Act or Sections 9 or 10 of the Rivers and Harbors Act: • WB-01, (0.09 acre) • WB-02, (0.03 acre) • WC-01, (237 linear feet, 0.08 acre) You are not required to obtain Corps authorization within the area(s) listed above. This determination only applies to the area(s) identified above and is based on a reasonable approximation of their location and boundaries. The basis for this determination is provided in the enclosed Memorandum for Record. The proposed work identified in your request and reflected on the attached drawing(s) does not require Corps authorization. If a change in design or location is contemplated, please contact our office to reassess permit requirements. Please note that you may need state or local authorizations. Agricultural Lands Information: This determination has been conducted to identify the location and extent of the aquatic resources for purposes of the Clean Water Act for the particular site identified in this request. This determination may not be valid for the Wetland Conservation Provisions of the Food Security Act of 1985, as amended. If you or your tenant are USDA program participants, or anticipate participation in USDA programs, you should discuss the applicability of an NRCS Certified Wetland Determination with the local USDA service center, prior to starting work. Appeal Process: If you object to this approved jurisdictional determination, you may request an administrative appeal under Corps regulations at 33 CFR 331. Enclosed you will find a Notification of Appeal Regulatory Division (File No. MVP-2025-00368-SSC) Page 2 of 2 Process (NAP) fact sheet and Request for Appeal (RFA) form. If you request to appeal this determination, you must submit a completed RFA form to the Mississippi Valley Division Office at the address shown on the form. In order for an RFA to be accepted by the Corps, the Corps must determine that it is complete, that it meets the criteria for appeal under 33 CFR 331.5, and that it has been received by the Division Office within 60 days of the date of the enclosed NAP. It is not necessary to submit an RFA form to the division office if you do not object to the determination in this letter. AJD Expiration: This AJD may be relied upon for five years from the date of this letter. However, the Corps reserves the right to review and revise the determination in response to information that was not considered during our initial review. Contact Information: If you have any questions, please contact me in our St. Paul District Office at 651-290-5268 or samantha.s.coungeris@usace.army.mil. In any correspondence or inquiries, please refer to the Regulatory file number shown above. Sincerely, Samantha Coungeris Project Manager Enclosures Project Figures, AJD MFR, Appeals Form cc: Malia Stone, Westwood Professional Services; malia.stone@westwoodps.com John Anderson, Pioneer Ridge LLC; johnbranderson@aol.com DEPARTMENT OF THE ARMY U.S. ARMY CORPS OF ENGINEERS, ST. PAUL DISTRICT 332 MINNESOTA STREET, SUITE E1500 ST. PAUL, MN 55101-1323 MVP 14 April 2025 MEMORANDUM FOR RECORD SUBJECT: US Army Corps of Engineers (Corps) Approved Jurisdictional Determination in accordance with the “Revised Definition of ‘Waters of the United States’”; (88 FR 3004 (January 18, 2023) as amended by the “Revised Definition of ‘Waters of the United States’; Conforming” (8 September 2023) ,1 MVP-2025-00368-SSC, MFR 1 of 1 2 BACKGROUND. An Approved Jurisdictional Determination (AJD) is a Corps document stating the presence or absence of waters of the United States on a parcel or a written statement and map identifying the limits of waters of the United States on a parcel. AJDs are clearly designated appealable actions and will include a basis of JD with the document.3 AJDs are case-specific and are typically made in response to a request. AJDs are valid for a period of five years unless new information warrants revision of the determination before the expiration date or a District Engineer has identified, after public notice and comment, that specific geographic areas with rapidly changing environmental conditions merit re-verification on a more frequent basis.4 On January 18, 2023, the Environmental Protection Agency (EPA) and the Department of the Army (“the agencies”) published the “Revised Definition of ‘Waters of the United States,’” 88 FR 3004 (January 18, 2023) (“2023 Rule”). On September 8, 2023, the agencies published the “Revised Definition of ‘Waters of the United States’; Conforming”, which amended the 2023 Rule to conform to the 2023 Supreme Court decision in Sackett v. EPA, 598 U.S., 143 S. Ct. 1322 (2023) (“Sackett”). This Memorandum for Record (MFR) constitutes the basis of jurisdiction for a Corps AJD as defined in 33 CFR §331.2. For the purposes of this AJD, we have relied on Section 10 of the Rivers and Harbors Act of 1899 (RHA),5 the 2023 Rule as amended, 1 While the Revised Definition of “Waters of the United States”; Conforming had no effect on some categories of waters covered under the CWA, and no effect on any waters covered under RHA, all categories are included in this Memorandum for Record for efficiency. 2 When documenting aquatic resources within the review area that are jurisdictional under the Clean Water Act (CWA), use an additional MFR and group the aquatic resources on each MFR based on the TNW, the territorial seas, or interstate water that they are connected to. Be sure to provide an identifier to indicate when there are multiple MFRs associated with a single AJD request (i.e., number them 1, 2, 3, etc.). 3 33 CFR 331.2. 4 Regulatory Guidance Letter 05-02. 5 USACE has authority under both Section 9 and Section 10 of the Rivers and Harbors Act of 1899 but for convenience, in this MFR, jurisdiction under RHA will be referred to as Section 10. MVP SUBJECT: 2023 Rule, as amended, Approved Jurisdictional Determination in Light of Sackett v. EPA, 143 S. Ct. 1322 (2023), MVP-2025-00368-SSC 2 as well as other applicable guidance, relevant case law, and longstanding practice in evaluating jurisdiction. 1. SUMMARY OF CONCLUSIONS. a. Provide a list of each individual feature within the review area and the jurisdictional status of each one (i.e., identify whether each feature is/is not a water of the United States and/or a navigable water of the United States). i. WB-01 (0.09 acre), non-jurisdictional ii. WB-02 (0.03 acre), non-jurisdictional iii. WC-01 (0.08 acre, 237 linear feet), non-jurisdictional 2. REFERENCES. a. “Revised Definition of ‘Waters of the United States,’” 88 FR 3004 (January 18, 2023) (“2023 Rule”) b. “Revised Definition of ‘Waters of the United States’; Conforming” 88 FR 61964 (September 8, 2023) c. Sackett v. EPA, 598 U.S. 651, 143 S. Ct. 1322 (2023) d. January 2023 Rule preamble at 88 FR 3090 e. “Memorandum To The Field Between The U.S. Department Of The Army, U.S. Army Corps Of Engineers And The U.S. Environmental Protection Agency Concerning The Proper Implementation Of ‘Continuous Surface Connection’ Under The Definition Of “Waters Of The United States” Under The Clean Water Act” (March 12, 2025) 3. REVIEW AREA. a. Project Area Size (in acres): approximately 13 acres b. Location Description: The review area is located within Sections 8 and 17, Township 116 North, Range 23 West, Carver County, Minnesota. c. Center Coordinates of the Project Site (in decimal degrees) Latitude 44.828244, Longitude -93.562135 d. Nearest City or Town: Chanhassen e. County: Carver f. State: Minnesota MVP SUBJECT: 2023 Rule, as amended, Approved Jurisdictional Determination in Light of Sackett v. EPA, 143 S. Ct. 1322 (2023), MVP-2025-00368-SSC 3 g. Other associated Jurisdictional Determinations (including outcomes): none 4. NEAREST TRADITIONAL NAVIGABLE WATER (TNW), THE TERRITORIAL SEAS, OR INTERSTATE WATER TO WHICH THE AQUATIC RESOURCE IS CONNECTED. N/A 5. FLOWPATH FROM THE SUBJECT AQUATIC RESOURCES TO A TNW, THE TERRITORIAL SEAS, OR INTERSTATE WATER. N/A 6. SECTION 10 JURISDICTIONAL WATERS 6: Describe aquatic resources or other features within the review area determined to be jurisdictional in accordance with Section 10 of the Rivers and Harbors Act of 1899. Include the size of each aquatic resource or other feature within the review area and how it was determined to be jurisdictional in accordance with Section 10.7 N/A 7. SECTION 404 JURISDICTIONAL WATERS: Describe the aquatic resources within the review area that were found to meet the definition of waters of the United States in accordance with the 2023 Rule as amended, consistent with the Supreme Court’s decision in Sackett. List each aquatic resource separately, by name, consistent with the naming convention used in section 1, above. Include a rationale for each aquatic resource, supporting that the aquatic resource meets the relevant category of “waters of the United States” in the 2023 Rule as amended. The rationale should also include a written description of, or reference to a map in the administrative record that shows, the lateral limits of jurisdiction for each aquatic resource, including how that limit was determined, and incorporate relevant references used. Include the size of each aquatic resource in acres or linear feet and attach and reference related figures as needed. a. Traditional Navigable Waters (TNWs) (a)(1)(i): N/A b. The Territorial Seas (a)(1)(ii): N/A c. Interstate Waters (a)(1)(iii): N/A 6 33 CFR 329.9(a) A waterbody which was navigable in its natural or improved state, or which was susceptible of reasonable improvement (as discussed in § 329.8(b) of this part) retains its character as “navigable in law” even though it is not presently used for commerce, or is presently incapable of such use because of changed conditions or the presence of obstructions. 7 This MFR is not to be used to make a report of findings to support a determination that the water is a navigable water of the United States. The district must follow the procedures outlined in 33 CFR part 329.14 to make a determination that water is a navigable water of the United States subject to Section 10 of the RHA. MVP SUBJECT: 2023 Rule, as amended, Approved Jurisdictional Determination in Light of Sackett v. EPA, 143 S. Ct. 1322 (2023), MVP-2025-00368-SSC 4 d. Impoundments (a)(2): N/A e. Tributaries (a)(3): N/A f. Adjacent Wetlands (a)(4): N/A g. Additional Waters (a)(5): N/A 8. NON-JURISDICTIONAL AQUATIC RESOURCES AND FEATURES a. Describe aquatic resources and other features within the review area identified in the 2023 Rule as amended as not “waters of the United States” even where they otherwise meet the terms of paragraphs (a)(2) through (5). Include the type of excluded aquatic resource or feature, the size of the aquatic resource or feature within the review area and describe how it was determined to meet one of the exclusions listed in 33 CFR 328.3(b).8 N/A b. Describe aquatic resources and features within the review area that were determined to be non-jurisdictional because they do not meet one or more categories of waters of the United States under the 2023 Rule as amended (e.g., tributaries that are non-relatively permanent waters; non-tidal wetlands that do not have a continuous surface connection to a jurisdictional water). WB-01, WB-02, and WC-01 are not TNWs, territorial seas, or interstate waters and are therefore not (a)(1) waters. WB-01 and WB-02 do not connect to any other wetlands or tributaries on or off-site. WB-01 and WB-02 were evaluated as potential (a)(4) waters but do not have a continuous surface connection to a jurisdictional water. WC-01 was evaluated as a potential (a)(3) water and was found to not meet this category because it is not a relatively permanent water with a continuous surface connection to a paragraph (a)(1) or (a)(3) water. The National Wetland Inventory (NWI) and National Hydrography Dataset (NHD) were both reviewed for the site and did not denote the presence of WB-01, WB- 02, or WC-01 or any other surface waters flowing through the site. Soils within this area are described as predominantly non-hydric, with two small areas in the southwest and northwest of the site denoted as hydric and predominantly hydric (Soil Survey). WB-01 and WB-02 are located within a topographically low area alongside Pioneer Trail (roadway). Both of these wetlands appear to have developed after 8 88 FR 3004 (January 18, 2023) MVP SUBJECT: 2023 Rule, as amended, Approved Jurisdictional Determination in Light of Sackett v. EPA, 143 S. Ct. 1322 (2023), MVP-2025-00368-SSC 5 Pioneer Trail was realigned further north from its original position (between 2006 and 2008, GoogleEarth Imagery). WB-01 flows into a culvert, a discrete feature, which does not directly abut a covered water. WB-02 is located west of WB-01 and is separated from WB-01 by uplands, based on the wetland delineation report submitted on behalf of the applicant. No other aquatic resources were identified in this area of the site. WC-01 was delineated based on the presence of a bed and bank within the channel. The watercourse flows east where it empties into a constructed stormwater basin. Hillshade and 3DEP (3D Elevation Program) Digital Elevation Modeling (DEM) were reviewed for this area and did not show a continuous surface connection to a jurisdictional water. The stormwater basin is surrounded by uplands. WB-01 and WB-02 do not have a continuous surface connection to a relatively permanent jurisdictional water and as such do not meet the definition of adjacent and cannot be evaluated as an (a)(4) adjacent wetland; therefore, WB-01 and WB-02 are non-tidal wetlands that are not jurisdictional under the 2023 Revised Definition of ‘Waters of the United States’; Conforming” 88 FR 61964 Final Rule. WC-01 is a tributary evaluated under (a)(3) and determined to not be a relatively permanent water with a continuous surface connection to a paragraph (a)(1) or (a)(3) water; therefore, this non-relatively permanent feature is not jurisdictional under the 2023 “Revised Definition of ‘Water of the United States’; Conforming” 88 FR 61964 Final Rule. 9. DATA SOURCES. List sources of data/information used in making determination. Include titles and dates of sources used and ensure that information referenced is available in the administrative record. a. Brandl Anderson – Bluff Creek Drive Wetland Delineation Report dated May 3, 2024 b. US Geological Survey, 3DEP Bare Earth DEM Dynamic service – hillshade and 3DEP DEM, accessed on April 14, 2025 c. Google Earth aerial imagery (1991 – present), accessed April 14, 2025 d. United States Geological Survey, National Hydrography Dataset, accessed on April 14, 2025 e. United States Fish and Wildlife Service, National Wetland Inventory, accessed August 13, 2024 MVP SUBJECT: 2023 Rule, as amended, Approved Jurisdictional Determination in Light of Sackett v. EPA, 143 S. Ct. 1322 (2023), MVP-2025-00368-SSC 6 10. OTHER SUPPORTING INFORMATION. N/A 11. NOTE: The structure and format of this MFR were developed in coordination with the EPA and Department of the Army. The MFR’s structure and format may be subject to future modification or may be rescinded as needed to implement additional guidance from the agencies; however, the approved jurisdictional determination described herein is a final agency action. Regulatory Division (File No. MVP-2025-00368-SSC) ENG FORM 6287, OCT 2024 PREVIOUS EDITIONS ARE OBSOLETE Page 1 of 5 U.S. Army Corps of Engineers (USACE) NOTIFICATION OF ADMINISTRATIVE APPEAL OPTIONS AND PROCESS AND REQUEST FOR APPEAL For use of this form, see Section 404 of the Clean Water Act, Section 10 of the Rivers and Harbors Act of 1899, and Section 103 of the Marine Protection, Research, and Sanctuaries Act; the proponent agency is CECW-COR. Form Approved – OMB No. 0710-0003 Expires 2027-10-31 DATA REQUIRED BY THE PRIVACY ACT OF 1974 Authority The authorities for requesting this information are Sections 9, 10, 13, and 14, Rivers and Harbors Act of March 3, 1899; Section 404, Clean Water Act; and Section 103 Marine Protection Research and Sanctuaries Act of 1972. Principal Purpose This information serves as notification to affected parties regarding the USACE administrative appeal options and process, as well as to facilitate requests for appeal of USACE decisions with which they disagree. Routine Uses Routine uses will include: (a) To serve as notification to affected parties of the Corps administrative appeal options and process and to facilitate requests for appeal of Corps decisions with which they disagree. (b) Records may be referred to the Department of Justice for possible criminal prosecution. (c) Records may be referred to other Federal, State, and local agencies for evaluation and enforcement purposes. Disclosure Disclosure of this information is voluntary on your part. However, failure of individual to provide requested information could result in inability to determine all pertinent information regarding a Department of the Army permit matter. The Agency Disclosure Notice (ADN) The Public reporting burden for this collection of information, 0710-0003, is estimated to average 1 hour per response, including time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate or burden reduction suggestions to the Department of Defense, Washington Headquarters Services, at whs.mc-alex.esd.mbx.dd-dod-information-collections@mail.mil. Respondents should be aware that notwithstanding any other provision of law, no person shall be subject to any penalty for failing to comply with a collection of information if it does not display a currently valid OMB control number. PURPOSE: This form is used to facilitate the initiation of the administrative appeals process. The appeals process allows an affected party to pursue an administrative appeal of certain Corps of Engineers decisions with which they disagree. Upon release, this form will also be available on the Corps website https://www.usace.army.mil/Missions/Civil-Works/Regulatory-Program-and-Permits/ Applicant: Pioneer Ridge, LLC c/o Christopher Contreras File Number: MVP-2025-00368-SSC Date: 4/14/2025 Documents Attached (select all that apply): Form Reference Section: ☐ INITIAL PROFFERED PERMIT (Standard Permit or Letter of permission) A ☐ PROFFERED PERMIT (Standard Permit or Letter of permission) B ☐ PERMIT DENIAL WITHOUT PREJUDICE C ☐ PERMIT DENIAL WITH PREJUDICE D ☒ APPROVED JURISDICTIONAL DETERMINATION E ☐ PRELIMINARY JURISDICTIONAL DETERMINATION F SECTION I The following identifies your rights and options regarding an administrative appeal of the above decision. Additional information may be found at https://www.usace.army.mil/Missions/Civil-Works/Regulatory-Program-and-Permits/appeals/ or Corps regulations at 33 CFR Part 331. Regulatory Division (File No. MVP-2025-00368-SSC) ENG FORM 6287, OCT 2024 PREVIOUS EDITIONS ARE OBSOLETE Page 2 of 5 A: INITIAL PROFFERED PERMIT: You may accept or object to the permit • ACCEPT: If you received a Standard Permit, you may sign the permit document and return it to the district engineer for final authorization. If you received a Letter of Permission (LOP), you may accept the LOP and your work is authorized. Your signature on the Standard Permit or acceptance of the LOP means that you accept the permit in its entirety, and waive all rights to appeal the permit, including its terms and conditions, and approved jurisdictional determinations associated with the permit. • OBJECT: If you object to the permit (Standard or LOP) because of certain terms and conditions therein, you may request that the permit be modified accordingly. You must complete Section II of this form and return the form to the district engineer. Upon receipt of your letter, the district engineer will evaluate your objections and may: (a) modify the permit to address all of your concerns, (b) modify the permit to address some of your objections, or (c) not modify the permit having determined that the permit should be issued as previously written. After evaluating your objections, the district engineer will send you a proffered permit for your reconsideration, as indicated in Section B below. B: PROFFERED PERMIT: You may accept or appeal the permit • ACCEPT: If you received a Standard Permit, you may sign the permit document and return it to the district engineer for final authorization. If you received a Letter of Permission (LOP), you may accept the LOP and your work is authorized. Your signature on the Standard Permit or acceptance of the LOP means that you accept the permit in its entirety, and waive all rights to appeal the permit, including its terms and conditions, and approved jurisdictional determinations associated with the permit. • APPEAL: If you choose to decline the proffered permit (Standard or LOP) because of certain terms and conditions therein, you may appeal the declined permit under the Corps of Engineers Administrative Appeal Process by completing Section II of this form and sending the form to the division engineer. This form must be received by the division engineer within 60 days of the date of this notice. C. PERMIT DENIAL WITHOUT PREJUDICE: Not appealable You received a permit denial without prejudice because a required Federal, state, and/or local authorization and/or certification has been denied for activities which also require a Department of the Army permit before final action has been taken on the Army permit application. The permit denial without prejudice is not appealable. There is no prejudice to the right of the applicant to reinstate processing of the Army permit application if subsequent approval is received from the appropriate Federal, state, and/or local agency on a previously denied authorization and/or certification. D: PERMIT DENIAL WITH PREJUDICE: You may appeal the permit denial You may appeal the denial of a permit under the Corps of Engineers Administrative Appeal Process by completing Section II of this form and sending the form to the division engineer. This form must be received by the division engineer within 60 days of the date of this notice. E: APPROVED JURISDICTIONAL DETERMINATION: You may accept or appeal the approved JD or provide new information for reconsideration • ACCEPT: You do not need to notify the Corps to accept an approved JD. Failure to notify the Corps within 60 days of the date of this notice means that you accept the approved JD in its entirety and waive all rights to appeal the approved JD. • APPEAL: If you disagree with the approved JD, you may appeal the approved JD under the Corps of Engineers Administrative Appeal Process by completing Section II of this form and sending the form to the division engineer. This form must be received by the division engineer within 60 days of the date of this notice. • RECONSIDERATION: You may request that the district engineer reconsider the approved JD by submitting new information or data to the district engineer within 60 days of the date of this notice. The district will determine whether the information submitted qualifies as new information or data that justifies reconsideration of the approved JD. A reconsideration request does not initiate the appeal process. You may submit a request for appeal to the division engineer to preserve your appeal rights while the district is determining whether the submitted information qualifies for a reconsideration. Regulatory Division (File No. MVP-2025-00368-SSC) ENG FORM 6287, OCT 2024 PREVIOUS EDITIONS ARE OBSOLETE Page 3 of 5 F: PRELIMINARY JURISDICTIONAL DETERMINATION: Not appealable You do not need to respond to the Corps regarding the preliminary JD. The Preliminary JD is not appealable. If you wish, you may request an approved JD (which may be appealed), by contacting the Corps district for further instruction. Also, you may provide new information for further consideration by the Corps to reevaluate the JD. POINT OF CONTACT FOR QUESTIONS OR INFORMATION: If you have questions regarding this decision you may contact: If you have questions regarding the appeal process, or to submit your request for appeal, you may contact: Name: U.S. Army Corps of Engineers, St. Paul District Name: Brian Oberlies, Regulatory Appeals Review Officer Street Address, City, State: 332 Minnesota Street Suite E1500 St. Paul, Minnesota 55101-1323 Street Address, City, State: Mississippi Valley Division P.O. Box 80 (Walnut Street) Vicksburg, MS 39181-0080 Phone: 651-290-5525 Phone: 601-634-5820 Email: brian.m.oberlies@usace.army.mil SECTION II – REQUEST FOR APPEAL or OBJECTIONS TO AN INITIAL PROFFERED PERMIT Regulatory Division (File No. MVP-2025-00368-SSC) ENG FORM 6287, OCT 2024 PREVIOUS EDITIONS ARE OBSOLETE Page 4 of 5 REASONS FOR APPEAL OR OBJECTIONS: (Describe your reasons for appealing the decision or your objections to an initial proffered permit in clear concise statements. Use additional pages as necessary. You may attach additional information to this form to clarify where your reasons or objections are addressed in the administrative record.) ADDITIONAL INFORMATION: The appeal is limited to a review of the administrative record, the Corps memorandum for the record of the appeal conference or meeting, and any supplemental information that the review officer has determined is needed to clarify the administrative record. Neither the appellant nor the Corps may add new information or analyses to the record. However, you may provide additional information to clarify the location of information that is already in the administrative record. RIGHT OF ENTRY: Your signature below grants the right of entry to Corps of Engineers personnel, and any government consultants, to conduct investigations of the project site during the course of the appeal process. You will be provided a 15-day notice of any site investigation and will have the opportunity to participate in all site investigations. Email address of appellant and/or agent Telephone number Signature of appellant or agent Date