[Name] [Company] Page 1 [Date] May 30, 2018

Ms. Division of Surface Water Ohio Environmental Protection Agency P.O. Box 1049 Columbus, Ohio 43216-1049

Re: Incomplete Section 401 Water Quality Certification Application Ohio EPA ID No. 113816 USACE No. 2009-836-OHR

Dear Ms. McLean:

As requested, we have reviewed your list of deficient items when receiving our Section 401 WQC application and have addressed them in the following manner:

 A wetland characterization analysis consistent with the Ohio Rapid Assessment Method (Completed ten page form for Wetland-7).  We have included the ORAM ten page form for Wetland 7.

 A use attainability analysis, if the project impacts a stream for which a specific aquatic life use designation has not been made (QHEI or HHEI) (A stream assessment should have been conducted on Ditch 2 since the Corps verified this as a stream in PJD).  We have included a QHEI for Solida Creek (500m from County Road 1 upstream) and HHEI for the ditch to be impacted (completed from inlet to storm systems 200 feet upstream).

 A specific and detailed mitigation proposal, including the location and proposed legal mechanism for protecting the property in perpetuity (Provide more detailed conceptual plans to present a clearer picture-details should be presented in a narrative and drawing for the minimal degradation and preferred alternatives for both stream and wetland mitigation.  We have included a detailed mitigation proposal with passive, ameliorative, and channel improvements/restorations to Solida Creek on LEDC property.

 Descriptions, schematics, and appropriate economic information of the applicant’s preferred non- degradation and minimal degradation alternatives for design and operation of the activity (Page 2 of Attachment A is cut off from item 10b. Schematics need legend and better explanation/more detail.  We are including minor revisions and update to Attachment A. Also including more detailed sketch of the degradation alternatives for design.

KER:CDM:lbjD:\Docs\2018-04-29\04c2771336e315d16608fcdf1bad2328.docx [Name] [Company] Page 2 [Date]  The delineation report of the waters of the United States in support of the 404 permit application (A delineation report was not submitted).  We have included the LEDC wetland delineation report (180 pages).

Please contact Carly Miller, Jim McCarthy, or me with any comments regarding this revision.

Sincerely,

STRAND ASSOCIATES, INC.®

Kristopher E. Ruggles

Enclosures c/enc: Teresa Spagna, Huntington District Corps of Engineers Mark Rollins, J&H Erectors Dr. Bill Dingus, Lawrence Economic Development Corporation

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