Heck, I don't even know what the ACoE is.
However, I have found that when dealing an unfriendly Gov't Dept. that there is usually some consultant, Lawyer or someone who knows the ropes and has their ear. I guess it sometimes take spreading some long green around. I went to the NRCS and got some help. Others haven't been so lucky and maybe it depends on budget or programs or lack of. I bet there is a pond builder who does know the ropes and I would look for them. You might also talk to the Engineering Company about the permit process and what the cost is if it is denied.
BTW, I have also found that State and/or Federal Representatives can sometimes help. I am also aware of several people who joined the local political parties, got to know people and asked for help.
