Not sure how prevalent this is throughout Corps districts, but one condition I heard Norfolk was including in permits was the following: “You shall submit Final Plans and Specifications for authorized activities for written Corps approval prior to initiation of permitted activities.”
Generally, I don't believe Corps Regulatory should care about verifying final engineering drawings unless there's a 408 permission involved and Corps Engineering needs to document changes to the federal project. Corps Regulatory rarely needs 100% details, just enough to evaluate environmental effects. The bottom line is that Regulatory approves proposals and that's really it. Applicants are entirely within their rights to seek authorization for preliminary designs, even if they know the final plans will probably change. It's the impacts to waters of the U.S., and associated environmental effects under various environmental laws, that are really relevant to Corps permitting, not the exact design. Part of the overall project located entirely in uplands could change after permitting and it shouldn't matter at all if those changes don't involve impacts in waters or within the Corps' scope of analysis. If the final plan does involve new/different impacts in the Corps' scope, the onus should be on the permittee to identify these new impacts and get them covered under a permit mod, or else risk getting penalized later for non-compliance. The extra oversight step Norfolk is adding seems unwarranted.
