By Hugh Crowell, MS, PWS  |   February 5th, 2016
On January 19, 2016 Ohio EPA closed the comment period for the proposed modification of the Section 401 Water Quality Certification of the Section 404 Nationwide Permits (NWPs) for Ohio, discussed in previous eblast. The proposed 401 modification has profound implications for any industry or regulated entity using NWPs for development in Ohio. Those activities particularly affected would be oil and gas exploration and production, road construction, natural gas pipeline and electrical line construction, other infrastructure and utility projects, and other regulated activities in streams that require any of thirty-one Nationwide Permits currently in effect.

Hull submitted detailed comments on the 401 modification reflecting our views of how the modified 401 certification could affect stream and wetland protection, current stream and wetland assessment practices, practical ramifications including timing and costs, and how the regulated community we serve could be affected.
The proposed 401 modification contains many important clarifications and eliminates certain arbitrary impact limits primarily affecting the shale gas pipeline industry, including the NWP-12 1,500-foot cumulative linear impact limit and the limit on construction of pipelines to a maximum of two HUC-8 watersheds. In addition, the current requirement for mitigation of temporary impacts to PEM wetlands is eliminated. On balance, however, the proposed 401 modification contains new regulatory review requirements and ambiguities concerning coverage that could render the Nationwide Permit process less effective at fulfilling its goal of expedited permitting for small surface water impacts with low potential for adverse effects.
Hugh Crowell, MS, PWS, Ecology & Wetlands Practice Leader
Hugh is the leader of Hull’s Ecology & Wetlands Practice. In his 27-year career, he has managed numerous environmental projects for brownfield, residential, commercial, industrial, county and municipal properties. Hugh is an experienced field plant ecologist and a certified Professional Wetland Scientist. He negotiates Clean Water Act §404 and §401 permits, oversees ecological risk assessments, performs water quality standards compliance analyses, and designs restoration and mitigation plans for streams and wetlands.
By William Rish, PhD  |   January 25th, 2016
What are the most important health and environmental risk factors of 2016?
There have been several recent surveys that have identified the top health and environmental risk factors of today.  According to the Global Risk Perception Survey of 900 experts, the top global environmental risks are:
By likelihood                                                               
  1. Extreme weather events 
  2. Natural catastrophes 
  3. Failure of climate change adaptation
  4. Water crises
By impact
  1. Water crises
  2. Spread of infectious diseases
  3. Failure of climate change adaptation
  4. Biodiversity loss and ecosystem collapse
Notice that failure of climate change adaptation and water crises are on both lists.  The World Health Organization (WHO) recently identified the leading health risk factors in higher income countries as, in order:
  1. Tobacco use
  2. Alcohol use
  3. Overweight and obesity
  4. High blood pressure
  5. High blood glucose
  6. Physical inactivity
  7. High cholesterol
  8. Illicit drugs
  9. Occupational risks
  10. Low fruit and vegetable intake
Notice that, with the exception of occupational risks, all of these are risks of self rather than risks created by others.  Also notice that these risks can be managed by one’s self.  The WHO also recently identified the leading global environmental health factors as:
  1. Unsafe water, poor sanitation and hygiene - particularly as a result of diarrheal disease (1.7 million deaths per year)
  2. Indoor smoke - from solid fuels such as dung, coal and wood (1.6 million deaths per year)
  3. Malaria - mostly African children under the age of five (1.2 million deaths per year)
  4. Urban air pollution - from vehicles, industries and energy production (800,000 deaths per year).
  5. Unintentional acute poisonings -  In developing countries, where two-thirds of these deaths occur, mainly from pesticides.(355,000 deaths per year)
  6. Climate change impacts including extreme weather events, changed patterns of disease, and effects on agricultural production (150,000 deaths per year).
Finally, the United States EPA recently named indoor air exposures as the top environmental health risk.  Looking over these lists, several thoughts come to mind.  I am fairly sure that 10 to 20 years ago chemically-contaminated sites and industrial water pollution would have been on some of the lists.  Environmental risk concerns are transitioning toward issues of a broader scale, such as climate change, the availability of water, regional air impacts, and community/population health impacts.  Also, the risk factors and priorities of higher income nations, such as the U.S., are very different from those of much of the world.  And lastly, the biggest sources of health risk in the U.S. appear to be mostly related to self-related factors that a person can control and/or reduce.  These findings suggest that a shift and refocus of environmental risk management policies and actions could be more effective in improving public health. 
William Rish, PhD, HullRAC Director
William (Bill) is a Principal and the Vice President of Hull's Environmental Market at Hull.  He also directs The HULL Risk Analysis Center (HullRAC) and has over 30 years of experience in risk assessment, decision analysis, and environmental consulting. 
Bill has been on the forefront of environmental liability evaluation, including the development of probabilistic techniques for quantifying environmental liability associated with contaminated sites in financial terms, and is published expert and expert witness in risk assessment and uncertainty analysis.
Bill received a Ph.D. in Engineering and Public Policy from Carnegie‑Mellon University.
By Jordan Rofkar, PhD  |   November 17th, 2015
Wetlands are so fundamentally important on the landscape that the federal government and State of Ohio require compensation for impacts, whether accidental or purposeful, to these critical ecosystems.  Mitigation wetlands are one of the keys to upholding the federal "no net loss" policy for wetlands.  By creating wetlands to replace impacted systems, we work to maintain the acreage and function of displaced ecosystems.
Wetland science evolves, often leading us away from the how-it's-always-been-done approach, and toward something new that fits contemporary dynamics of environment, economy, and society.  Such was the case when ODOT approached Hull about developing an alternative method for assessing mitigation wetlands. 
Current assessment procedures provide glimpses into wetland conditions; but wetlands develop over time, and their functional value can't be defined solely by the plant and animal communities they support. 
We decided to build on that sentiment, and have created an assessment method that looks at the entire suite of wetland functions, rather than just acreage or biodiversity.  We've constructed a set of scoreable metrics that we use to infer the probability of a wetland performing hydrological, water quality, biodiversity, and societal functions. 
Our proposed method isn't unprecedented.  In fact, it's built on a foundation of functional assessment methods from the federal government and multiple states around the nation.  As a state with incredible wetland resources, Ohio is poised to be a leader in the area of wetland functional assessment.
So far, the response from the regulated community has been great.  Many are interested in innovative approaches that judge mitigation success across a range of functions.  Field trials have gone well, and we're getting input from experienced wetland scientists.  We're getting the direction the science leads us.
If you're interested in learning more about the Ohio Mitigation Wetlands Assessment Method (OMWAM) please reach out to us. We're eager to hear from you.
Jordan Rofkar, PhD, Scientist II
Jordan provides technical guidance for projects involving phytoremediation, nutrient runoff, and other environmental constituents.  He routinely assists in aquatic and terrestrial field sampling and data analysis.  Jordan also surveys terrain to help guide proposed pipeline placements around sensitive environmental resources.
Jordan holds a Doctor of Philosophy, Biology and a Master of Science, Biology, from University of Toledo, as well as a Bachelor of Arts, Ecology and Evolutionary Biology from University of Arizona.
By Mark Schmidt, PG  |   October 7th, 2015
Earlier this summer, the Ohio Legislature and Governor John Kasich approved House Bill 64, the state budget bill, which includes a new $20 million fund dedicated to cleaning up former and abandoned gas station sites around Ohio. The fund is built into the annual operating budget for the Ohio Development Services Agency (ODSA), which will oversee the new Abandoned Gas Station Cleanup Grant Program.
The program is targeted at helping communities, developers, and eligible property owners address “Class C release” sites, with more than 400 Class C properties currently listed throughout Ohio. ODSA is currently developing the grant application, which is expected to be released later this fall.
These new grant funds can be used at Class C sites to:
  • Conduct up to $100,000 in environmental site assessment activities; and
  • Complete up to $500,000 of site remediation or cleanup activities.
To be eligible for the program, the property must be a Class C site (meaning the state has certified that the responsible party is incapable of completing assessment and cleanup of the site), and the applicant for funds cannot have caused or be a contributing party to the contamination at the property. Eligible applicants include municipalities and other political subdivisions, as well as organizations that enter into redevelopment agreements with a political subdivision. Once available, completed applications will be submitted directly to ODSA and reviewed by the agency upon receipt.
Now is the time to take stock of eligible Class C sites in your community. Let HULL help you plan your next redevelopment project!
Mark Schmidt, PG, Senior Project Manager
Mark is a Professional Geologist with 24 years of experience conducting and managing environmental investigations and corrective actions at petroleum release sites, including retail sites, refinery, terminal, and pipeline facilities. He specializes in assessment, risk-based corrective action, and remediation of petroleum underground storage tank sites, and has provided project management and technical assistance at more than 200 retail sites in Illinois, Indiana, Ohio, Pennsylvania, and Tennessee. Mark holds a Master’s of Science and a Bachelor of Science in Geology from Kent State University.
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