25
MDE Permits – From Design Office to the Field Highway Operations Subcommittee 2010 MdQI Conference January 27, 2010 MDE Permits – From Design Office to the Field…and Back!
MDE Permits – From Design Office to the Field
Highway Operations Subcommittee
2010 MdQI Conference
January 27, 2010
MDE Permits –From Design Office to the Field…and Back!
MDE Permits – From Design Office to the Field
MDE Permits –From Design Office to the Field…and Back!
• Goal of the Session: To discuss the necessity of making field changes and the appropriate procedures to follow in order to keep construction moving forward while maintaining compliance with all environmental stewardship commitments
• Focus: Conventional Design-Bid-Build projects
• Session will NOT address Design-Build
MDE Permits – From Design Office to the Field
Session Outline
• Introductions and Problem Statement
– Overview of current process and issues
• Panel Statements
– Discussion points from MDE, HHD, OED, MTBMA
• Response to Questions from Panelists
• Questions and Answers
• Report out on Priority Items
MDE Permits – From Design Office to the Field
Panel Members• SHA-OED
– Todd Nichols
– Don Hoey
• SHA-HHD
– Karuna Pujara
– Steve Buckley
• MDE
– Ken Pensyl
• MTBMA
– Mike Veid, J.B. Fay Company
• Moderator
– Chris Fronheiser, AECOM
MDE Permits – From Design Office to the Field
Problem Statement and Issues
• Contractors and field personnel are feeling constrained from making field changes due to time and effort required to process (and authorize) the change
• SHA and MDE have standard operating procedures and guidelines in place which must be adhered to in order to protect the natural environment and sensitive features
MDE Permits – From Design Office to the Field
Design Steps to Permit Approval
• New regulations require a 3 stage approval process
• Initial SWM/ESC concept - PI stage or earlier.
• Site Design Approval –Semi final
• Final Approval – Final Review
• Each stage submittal may require several reviews
• Reviews performed by Consultant Reviewers according to SHA set priority.
• Final approval by MDE
Highway Hydraulics Division
MDE Permits – From Design Office to the Field
Erosion & Sediment Control Plans
• Critical Elements
– Sequence of Construction
• Needs to be specific and detailed
– Limit of Disturbance
• Anywhere earth is disturbed
– Design and placement of controls
– Borrow, stockpile areas usually need to be identified by contractor and approved by SHA and MDE
Highway Hydraulics Division
MDE Permits – From Design Office to the Field
Modifications• Field Changes (subject to MOU and MDE Inspector)
• Modifications – OOC62
– Approval by PE
– Review and process by HHD (point of contact 410-545-8393)
• Ensure plan meets SHA criteria
• Ensure plan is approvable by MDE
» Quality of Submittals vary
– Submit to MDE » HHD coordinates project review priority with MDE
» Large number of pending reviews at any given time
» Turnaround times are generally 1-2 days
» Modifications given highest priority but only if we know of submittal.
Highway Hydraulics Division
MDE Permits – From Design Office to the Field
Modification Example - Original
Highway Hydraulics Division
MDE Permits – From Design Office to the Field
Modification Example - Revised
Highway Hydraulics Division
MDE Permits – From Design Office to the Field
Highway Hydraulics Division
MDE Permits – From Design Office to the Field
Highway Hydraulics Division
MDE Permits – From Design Office to the Field
Wetland/Waterways Permits
• Process - Avoidance/Minimization & Multi-Agency Coordination
• Changes often times require Multi Agency Coordination
• Commonly requested changes:
– Stream Diversion/Maintenance Of Stream Flow
– Stream Closure Time of Year Waiver requests
– Adding additional riprap to streams
Office of Environmental Design
MDE Permits – From Design Office to the Field
Wetlands/Waterway Permits
• Communication – Permit Modifications take time and should be coordinated EARLY !
– Require revisions to engineering plans
– AMMR still required and considered
– Time frame – expect weeks to months for approvals
Office of Environmental Design
MDE Permits – From Design Office to the Field
Wetlands/Waterways Permits
• Environmental Monitors – On projects with “significant” environmental resources
– “Eyes and Ears” of CORPS/MDE and may or may not be a permit requirement
– Part of the Environmental Compliance Team –
• OOC, District Construction, QA, Design
Office of Environmental Design
MDE Permits – From Design Office to the Field
Quality Assurance = The Compliance Check
• Overview of Quality Assurance role
– Quality Assurance – to independently review and report on a project’s compliance at any one time
– To measure a project with a 100% compliance in mind
Office of Environmental Design
MDE Permits – From Design Office to the Field
• Opportunities to capture within the Quality Assurance program:
– To understand the environmental agenda and it’s intended compliance requirements
– To identify program improvements to forward the environmental commitment
– To encourage communication, teamwork and partnerships
– To bridge gaps between design and construction
Office of Environmental Design
Quality Assurance = The Compliance Check
MDE Permits – From Design Office to the Field
Quality Assurance = The Compliance Check
• Protocol for making field changes:
– Propose an idea, submit a request via OOC62 process, get SHA’s review and approval (at field level),
– If minor(per MOU), seek MDE field representative review and approval.
– If major (per MOU), seek MDE field representative input, seek SHA’s HHD review and approval (as well as any other division/office review and approval), seek MDE (plan review) review and approval.
Office of Environmental Design
MDE Permits – From Design Office to the Field
Quality Assurance = The Compliance Check
• Protocol for making field changes (cont.)
– OOC62 – Is designed for E&S control, however, it serves as a platform for varying environmental requests (because relating issues are usually involved).
Office of Environmental Design
MDE Permits – From Design Office to the Field
Quality Assurance = The Compliance Check
• Common reasons for not approving or delaying a field change:
– Lack of required information
– Incomplete package submittal
– Misdirection of package
– Doing work before it’s approved
• Remember - it is the details that matter!
Office of Environmental Design
MDE Permits – From Design Office to the Field
Contractor Issues and Concerns
• Desire for flexibility in making changes:
– What can be approved same day “in-the-field”
– Define what MDE considers a “minor modification” change and what is a “major modification” change
– Know who the “appropriate approval authority” is for submitting your modifications
MTBMA
MDE Permits – From Design Office to the Field
Contractor Issues and Concerns
• Need to know more at pre-con about what the process is:
– Provide written instructions and standard forms necessary for submitting your modifications
– Know who the “appropriate approval authority” is for submitting your modifications
MTBMA
MDE Permits – From Design Office to the Field
Contractor Issues and Concerns
• Apply the partnering philosophy to improve the process:
– What is the partnering philosophy?
“a process…in which all participants in a project…work to achieve objectives through improved communication and cooperation” (Field Guide
to Partnering on MSHA Projects)
– Use the issue resolution chart for resolving modification requests
MTBMA
MDE Permits – From Design Office to the Field
Contractor Issues and Concerns
• Importance of education for primes & subs:
– Require that all Supervision be certified through MDE/SHA training courses
– Require that all personnel involved with E/S attend the pre-cons and E/S meetings
– Require re-certification of all Supervision on a periodic basis
MTBMA
MDE Permits – From Design Office to the Field
QUESTIONS AND ANSWERS
