Dear Brig. Gen. Holland,
We write to you today concerning the revised real estate administrative fee schedule to be implemented at reservoirs and waterways in the South Atlantic Division (SAD) of the U.S. Army Corps of Engineers (Corps).
As you know, on June 6, 2019, the Corps announced the implementation of a revised real estate administrative fee schedule for dock and land-based facility permits along shorelines of Federal reservoirs and waterways in the South Atlantic Division. This revised schedule, to take effect on January 1, 2020, includes an increase in fees for new and re-issue dock and land-based facility permits. Under the revised fee schedule, the cost to individuals for a new dock or facility permit will increase from $400 to $835 and the cost for a re-issue permit will increase from $175 to $835.
The announced increase in fees for new, re-issue, and modified permits for docks and land-based facilities is unexpected and significant. These increases could have a serious impact on individuals living on or near a number of reservoirs and waterways in the South Atlantic Division, but it does not appear that any public input was sought or considered. We understand that there may be a periodic need to update fees in order to meet the costs incurred by programs, however such increases must be paired with transparency and clear explanation as to why they are warranted. Unfortunately, that has not happened in this case. Additionally, the sudden, steep increase in the cost of permits rather than a gradual phase-in suggests a lack of foresight on behalf of the South Atlantic Division. Finally, we find it difficult to believe that the Corps would incur the same costs to renew or modify an existing permit as it would to issue a new permit.
We therefore request that your office:
1) Provide justification for the two- and five-fold increase in fees for new and re-issue permits;
2) Provide explanation of the process through which the Corps arrived at the decision to significantly raise fees, and why no public input was considered;
3) Provide explanation for why the Corps chose such a significant increase at once, rather than phase in a gradual raise in fees;
4) Provide explanation for why renewing or modifying an existing permit should be as expensive as the cost of a new permit.
We respectfully request that you respond no later than June 28, 2019. Please do not hesitate to contact our offices should you have any questions. We look forward to your prompt attention to this matter.