General Permits: An Environmental Minefield
August 2016
Citation:
46
ELR 10668
Issue
8
At bottom, Eric Biber and J.B. Ruhl argue in their recent article that general permits are a panacea for many of the difficult permitting issues that modern administrative agencies face. We have no quarrel with their conclusion in theory; however, in practice—at least in the environmental arena—agencies such as the U.S. Army Corps of Engineers often abuse general permits.