3
Assessment of the Corps' Planning Processes

The Corps Planning Process

The U.S. Army Corps of Engineers plans, constructs, and operates water resource projects for a variety of purposes. The Corps' main water planning and development activities include flood damage reduction, navigation enhancement, aquatic ecosystem restoration, hurricane damage prevention, and beach protection. The Corps' water resources project planning procedures consist of two planning phases: a reconnaissance study and a feasibility study. This two-phase planning process was formalized with the enactment of the federal Water Resources Development Act of 1986 (WRDA '86). According to a special Corps task force that reviewed the planning process, "The fundamental purpose of the Corps process is to provide enough information to federal and nonfederal decision makers to determine that implementation of a proposed action is a wise investment decision" (USACE, 1996b).

Corps planning guidance comes from several sources. The two most important are the federal Principles and Guidelines for Water and Related Land Resources Implementation Studies, and the Corps document "Guidance for Conducting Civil Works Planning Studies," also known as Engineering Regulation (ER) 1105-2-100 (USACE, 1990). This document contains the P&G and provides advice on how they are to be used. The P&G provide planning guidelines for the Corps and three other federal water-planning agencies (the Bureau of Reclamation, the Natural Resource Conservation Service (NRCS), and the Tennessee Valley Authority), whereas ER 1105-2-100 is specific to the Corps. Additional guidance is provided by the Digest of Water Resources Policies and Authorities , guidance letters, and a series of engineering regulations (ERs) and engineering circulars (ECs).

The Principles and Guidelines were approved in 1983 and enacted via the Water Resources Council (WRC). The P&G replaced the Principles and Standards for Planning Water and Related Land Resources, which were adopted in 1972. Like the P&G, the Principles and Standards were enacted to provide a comprehensive framework for analyzing water development alternatives and were intended to be used consistently across federal water agencies.

There are several important differences between these two documents. The P&S framework included four sets of objectives: (1) national economic development (NED); (2) environmental quality (EQ); (3) regional economic development (RED); (4) other social effects (OSE). These four accounts encompass the significant effects of a water development project according to the National Environmental Policy Act



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--> 3 Assessment of the Corps' Planning Processes The Corps Planning Process The U.S. Army Corps of Engineers plans, constructs, and operates water resource projects for a variety of purposes. The Corps' main water planning and development activities include flood damage reduction, navigation enhancement, aquatic ecosystem restoration, hurricane damage prevention, and beach protection. The Corps' water resources project planning procedures consist of two planning phases: a reconnaissance study and a feasibility study. This two-phase planning process was formalized with the enactment of the federal Water Resources Development Act of 1986 (WRDA '86). According to a special Corps task force that reviewed the planning process, "The fundamental purpose of the Corps process is to provide enough information to federal and nonfederal decision makers to determine that implementation of a proposed action is a wise investment decision" (USACE, 1996b). Corps planning guidance comes from several sources. The two most important are the federal Principles and Guidelines for Water and Related Land Resources Implementation Studies, and the Corps document "Guidance for Conducting Civil Works Planning Studies," also known as Engineering Regulation (ER) 1105-2-100 (USACE, 1990). This document contains the P&G and provides advice on how they are to be used. The P&G provide planning guidelines for the Corps and three other federal water-planning agencies (the Bureau of Reclamation, the Natural Resource Conservation Service (NRCS), and the Tennessee Valley Authority), whereas ER 1105-2-100 is specific to the Corps. Additional guidance is provided by the Digest of Water Resources Policies and Authorities , guidance letters, and a series of engineering regulations (ERs) and engineering circulars (ECs). The Principles and Guidelines were approved in 1983 and enacted via the Water Resources Council (WRC). The P&G replaced the Principles and Standards for Planning Water and Related Land Resources, which were adopted in 1972. Like the P&G, the Principles and Standards were enacted to provide a comprehensive framework for analyzing water development alternatives and were intended to be used consistently across federal water agencies. There are several important differences between these two documents. The P&S framework included four sets of objectives: (1) national economic development (NED); (2) environmental quality (EQ); (3) regional economic development (RED); (4) other social effects (OSE). These four accounts encompass the significant effects of a water development project according to the National Environmental Policy Act

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--> (NEPA) of 1969. The P&S required water project alternatives to be evaluated in relation to their impacts on the two principal planning objectives, NED and EQ. The other two objectives could also be assessed but were not required for all projects. The P&G represented an important departure from the P&S in that they required only one alternative to be developed during project planning, the NED option. Other alternatives may be developed but are not required. The NED account is the water development alternative designed to maximize a project's marginal benefits and is to be "consistent with protecting the Nation's environment, pursuant to national environmental statutes, applicable executive orders, and other Federal planning requirements" (U.S. Water Resources Council, 1983). Details of how the NED plan is to be calculated are provided within the P&G. The other critical difference between the two planning documents is that the P&G serve merely as recommended guidance that has no legal force, whereas the P&S constituted requirements. The P&G define a six-step planning process, which guides both the reconnaissance and feasibility planning stages. Those six steps are: Specify problems and opportunities. Inventory and forecast conditions. Formulate alternative plans. Evaluate effects of alternative plans. Compare alternative plans Select recommended plan These six steps are not necessarily applied sequentially in Corps planning; rather, the activities of problem definition, goal setting, and comparing project alternatives can be conducted simultaneously and recur throughout project planning. The concept of "planning" defies exact description but is explained in a Corps Institute for Water Resources (IWR) document (Yoe and Orth, 1996) as: " . . . the deliberate social or organizational activity of developing an optimal strategy for solving problems and achieving a desired set of objectives." Although technical analyses are part of the planning process, the Corps' notion of planning extends beyond technical activities such as siting and design. The Corps seeks to solve water related problems through a structured, rational planning approach. The Corps' studies and projects typically originate with a request for assistance from a community with a water resource problem beyond its means to address. They can also originate within the Corps, which may identify a water resource problem or opportunity. Before the Corps can get involved, it needs two types of authority from the Congress: study authority and budget authority. A study authority allows the Corps to investigate the problem. Once this is granted, the budget authority to spend federal funds can be provided in an annual appropriations act passed by Congress. If there is no authority for the Corps to study the problem, a congressional member may request a study authority from the Senate (Committee on Environment and Public Works, Subcommittee on Transportation and Infrastructure) or the House of Representatives (Committee on Transportation and Infrastructure, Subcommittee on Water Resources and Environment). Once congressional approval is obtained, the

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--> study is assigned to one of Corps' 36 local district offices. The district may then request funds through the federal budget process to conduct the study's first phase, the reconnaissance study. Once those funds are apportioned by the Office of Management and Budget (OMB), the district office may begin the study of the particular water resource problem. As of 1996, it took the Corps an average of 1.5 years to conduct reconnaissance studies, and 3.4 years for feasibility studies (USACE, 1996b), plus roughly a one year gap in between. Figure 3.1 is an idealized timeline, according to this committee, of the Corps' two-stage planning process, the reconnaissance and feasibility stages. The Reconnaissance Phase The reconnaissance phase of a Corps study is used to better understand the nature of a water resource problem and to determine the likelihood of a plan the Corps can eventually implement. Reconnaissance studies are fully funded by the federal government. The reconnaissance study provides a recommendation either to proceed to the feasibility study or halt the planning efforts. Today the Corps' reconnaissance phase is to be completed in no more than one year and is to cost no more than $100,000. Conducted by a Corps district office (Figure 3.2), the reconnaissance study also examines the likelihood of enlisting local sponsorship. Upon completion of the reconnaissance report, the Corps and local sponsor negotiate a project study plan (PSP) and a feasibility cost-sharing arrangement (FCSA). These are part of the same process, as the FCSA reflects the terms agreed to by the Corps and local sponsor in the PSP. The PSP includes specific engineering and scientific studies and management activities that need to be conducted. Although the specifics vary from study to study, the Corps and local sponsor must agree on the following terms: task descriptions: what needs to be done and at what level of detail and effort? task responsibilities: who will pay for each task? task milestones: how long will each task take, and when will they be completed? The Corps and a local sponsor—usually a nonfederal agency that signs a feasibility cost-sharing agreement and/or the project cooperation agreement (PCA) with the Corps—negotiate several other points, including study schedule, study cost, mix and value of cash and in-kind products and services, and the review of the work. Local sponsors are part of a broader category of "local interests," which refers to a broad group of people and organizations with interests in a Corps project, some of whom may oppose the project.

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--> Figure 3.1 Recommended Corps planning study timeline.

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--> Figure 3.2 Division and districts of the U.S. Army Corps of Engineers. Source: http://www.usace.army.mil.

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--> Many terms of the FCSA are non-negotiable. For example, cost-sharing arrangements of the feasibility study are mandated by WRDA '86, calling for a 50-50 split between the Corps and local sponsor. In addition, the local sponsor can contribute a maximum of 25 percent of the total study costs through in-kind products and services (50 percent of their 50 percent contribution). The FCSA negotiations may require up to nine months, but the FCSA should be signed about one year after the beginning of the reconnaissance phase, assuming feasibility study funds are appropriated. Throughout the course of the FCSA, the Corps may receive input from Corps headquarters in Washington, D.C., and also receives public input through a variety of means. The FCSA is signed when the sponsor and Corps reach agreement on the negotiable terms and Congress appropriates feasibility study funding. The Feasibility Phase Soon after the FCSA is signed, the Corps announces the project's feasibility study and holds a public workshop. The first several months of the feasibility stage are spent formulating alternative plans. For example, in addressing a flood problem the Corps might consider a range of strategies, including construction of a dam or levees, channel improvements, nonstructural techniques, or combinations of approaches. They would also examine the appropriate design characteristics revealed in preliminary studies (e.g., the level of flood protection—50 years, 100 years, 200 years, or greater). During this stage the Corps conducts project design analyses (including engineering and hydrologic studies), project costs estimates, and benefit-cost estimates in accord with the P&G and the "Guidance for Conducting Civil Works Planning Studies" (ER 1105-2-100). Although the Corps does not conduct a highly detailed investigation for every project alternative, these studies are inherently intensive and time-consuming. Reducing the time spent on these studies may be possible but may also compromise their quality. Among these alternative plans (formulated by the Corps district office in collaboration with the sponsor, the stakeholders, and Corps headquarters), the Corps must identify the NED alternative. Although it represents the optimal national economic alternative, the NED plan may not be the preferred alternative. For example, the NED plan may offer protection to the 100-year flood level, but the local sponsor may desire protection against a 200-year flood. The Corps may eventually construct a project that goes beyond the NED plan, provided the sponsor is willing to bear some portion of the additional costs. An alternative formulation briefing (AFB) is held when the Corps district office is prepared to present the alternative plans, the NED plan, and the tentatively selected plan. Though the AFB is not mandatory, the Corps district office is strongly encouraged to convene the briefing to prevent problems from arising later in the study. At the AFB, the Corps district office addresses policy issues identified by the division, district, or Corps headquarters. Sponsors are strongly encouraged to attend the AFB discussions, especially technical and other experts of sponsor groups. The Corps clearly feels that local sponsor participation is essential for a successful briefing.

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--> Following the AFB, the district completes the draft feasibility report (as well as an environmental impact statement, or EIS). The draft feasibility report is distributed for a 45-day public review and sent to Corps headquarters for Washington-level review (i.e., the Corps, the Secretary of the Army, the states, other relevant federal agencies, and the OMB). The Corps then holds another public meeting (roughly six months after the AFB) and incorporates comments from the public and headquarters into a revised feasibility report. When the project sponsor and the Corps agree on a final plan, the feasibility study ends with the signing of the division engineer's notice, which represents a public announcement that the top Corps-level field official recommends approval of the project and allows the final feasibility report to be sent to Corps headquarters for review. Preconstruction Engineering and Design and the Chief's Report The preconstruction engineering and design (PED) phase begins soon after the division engineer's notice. The Corps district office conducts the PED phase, which includes the first set of specifications and a clear identification of the lands, easements, rights of way, relocations, and disposal areas (LERRDs) required. PED often takes two years or longer. The planning process is completed with the signing of the final report by the chief of engineers. This is typically a short (five- to six-page) letter addressed to the Secretary of the Army, in which the Chief of Engineers recommends approval of the project. Types, Length, and Costs of Corps Planning Studies Since WRDA '86, the Corps has initiated about 50 reconnaissance studies a year. As shown in Table 3.1, 51 percent of those projects were for flood damage reduction, with navigation projects accounting for 17.5 percent. Nine percent of the projects were for environmental restoration, and roughly 9 percent were for hurricane damage prevention (4.4 percent) and shoreline and beach protection (4.4 percent). Of the 566 reconnaissance studies started in 1986-1996 (Table 3.1), 525 were actually completed. Of those 525, feasibility studies were initiated on 163 projects, or 31 percent of the projects conceived at the reconnaissance stage. The data in Table 3.1 are for the 82 feasibility studies completed by 1996. Regardless of purpose, projects have about an equal chance of progressing to the feasibility stage. For example, Table 3.1 indicates that 51.2 percent of the feasibility studies were for flood damage reduction, nearly the identical percentage that flood damage reduction studies represent at the reconnaissance stage. An exception may be the Corps' environmental projects. Although the statistical sample that the committee evaluated was relatively small, environmental projects were only half as likely to proceed to the feasibility stage.

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--> Table 3.1 Profile of Corps Studies, 1986-1996   Reconnaissance Studies Feasibility Studies Project Type Number Percentage Number Percentage Flood damage prevention 288 50.9 42 51.2 Navigation 99 17.4 22 26.8 Hurricane damage prevention 25 4.4 6 7.3 Shoreline/beach protection 25 4.4 4 4.9 Environmental 51 9.0 4 4.9 Water supply 22 3.9 3 3.7 Other 56 10.0 1 1.2 Total 566 100.0 82 100.0   Source: USACE, 1997.

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--> Length of Corps Planning Studies Since 1990, the average reconnaissance study has taken about 13.5 months to complete. Tables 3.2 and 3.3 show elapsed planning time for select Corps reconnaissance studies (495 studies), and Corps reconnaissance and feasibility studies (54 studies), respectively. The data indicate that the average time to complete both the reconnaissance and feasibility studies is approximately 5.6 years, roughly the same as those reported in 1996 by a special Corps task force on shortening the planning and design process (USACE, 1996b). Costs of Corps Planning Studies Table 3.4 provides detailed cost information on 495 of the reconnaissance studies initiated from 1985 to 1996. The data are arranged on the basis of calendar years and assigned total reconnaissance planning costs for each project the year it was started, regardless of whether the document was finished that year. Reconnaissance studies have become more expensive in current dollars, but have remained constant in real terms. The average study started between 1985 and 1990 cost roughly $320,000, whereas the average study between 1991 and 1996 cost roughly $410,000 (which includes labor, travel, consultant fees when necessary, and internal overhead costs when appropriate). These costs have increased at roughly the rate of inflation. As noted in the previous section, less than a third of the reconnaissance studies progressed to the feasibility stage. The final column of Table 3.4 shows total expenditures on reconnaissance studies that did not result in a feasibility report. In fact, for all studies initiated in the years 1985-1993, 63.9 percent of the dollars budgeted for reconnaissance studies were spent without further expenditures for a feasibility study. This amounts to over $79 million during that period to determine that there was either no federal interest or that the local sponsor was unable or unwilling to share the costs of further evaluation. A 1996 initiative by Corps Headquarters (HQUSACE) mandating the $100,000 limit on the cost of reconnaissance studies will have a significant impact on the planning process, as more than 90 percent of the studies conducted in 1985-1996 exceeded the limit. Complete reconnaissance and feasibility cost data were available for a subset of 54 of the 588 projects that the committee reviewed. Average costs are presented in Appendix B. Federal Budgeting and Authorization Before 1986, nonfederal sponsors were far less involved in arranging project financing, as all funding for reconnaissance and feasibility studies was provided by the federal government. Nonfederal sponsors today must budget funds and other assets for planning activities, design, and construction in a more timely manner and in concert with federal budgeteers. Longer lead times, variable outcomes of federal

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--> Table 3.2 Elapsed Time of Corps Reconnaissance Studies, 1985-1996 Year Study Initiated Number of Reconnaissance Reports That Year Average Time to Complete (months) Range of Time to Complete (months) 1985 18 22.5 12-39 1986 28 12.7 1-26 1987 11 16.2 11-34 1988 77 14.8 7-24 1989 35 14.7 12-24 1990 42 13.1 5-19 1991 71 14.0 8-20 1992 29 13.8 9-22 1993 43 13.7 6-19 1994 69 13.0 4-21 1995 34 13.7 11-19 1996 38 - - budgeting processes, and unforeseen costs and cost overruns all increase uncertainty for nonfederal partners. Some projects in the federal interest may not have been undertaken because the Corps could not adequately assure that studies would be completed on time and within budget. The Corps' budgeting process is lengthy, taking up to two years lead time. The administration's budgeting process takes roughly one year, plus a minimum of nine additional months for the congressional process. After receiving guidance from the OMB for the impending budget cycle, Corps districts send proposed budgets to Corps divisions, which then send the requests to Corps headquarters. Annual budget requests generated through this process consist of individual amounts for well over a thousand studies, projects, and programs, including reconnaissance studies, feasibility studies, PED, construction projects, and operation and management (O&M) projects and programs. Headquarters then assembles its request (usually in

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--> Table 3.3 Duration of Selected Studies (54 Projects)     Average Elapsed Time (months)   Project Purpose Reconnaissance Between Feasibility Total Elapsed Time Shoreline beach protection (2) 12.00 21.50 47.00 80.5 Navigation/shallow draft (5) 12.40 8.60 32.80 53.8 Navigation/inland waterways (3) 12.00 7.33 40.67 60.0 Navigation/deep draft (10) 11.70 9.50 44.50 65.7 Navigation/other(1) 16.00 6.00 59.00 81.0 Hurricane damage protection (4) 15.25 15.50 38.75 69.5 Flood damage protection (27) 13.11 11.44 43.85 68.4 Environmental (2) 12.00 13.50 31.50 57.0 Average (54) 12.85 11.24 43.33 67.42 July or August) for submission to OMB, through the Assistant Secretary of the Army for Civil Works. The request is then reviewed for two to three months (September or October to December). All of this must occur before the president's budget is presented in January or February of the following year. Congress then has until October 1 to enact an appropriations bill. Because the total amounts requested by Corps districts may exceed what the president's budget includes, congressional committees may require the Corps to determine its "capability" during the fiscal year: its capacity to process projects and studies, considering not only budgetary but also personnel constraints, sound engineering practices, and the timing of available funds. Each Corps study and project is required to be appropriately authorized. The Corps undertakes civil works studies in response to authorizations from Congress. Committee resolutions are the most common authorization vehicles for studies. As mentioned earlier, authorizations may be contained in public laws and resolutions of either the Senate or House. This is especially the case when a study's scope involves a review of a basin or navigation report previously studied by the Corps. Streamlining the Planning Process In 1996 the Assistant Secretary of the Army for Civil Works ordered the planning process to be shortened (Corps Planning Guidance letter 97-10, 1997; see Appendix A). In response, the Corps appointed a special task force on shortening the planning process, which began its study with the following premises: local sponsors often feel strongly that the Corps' planning and design process is too long; it is important to understand the impacts of any changes in the Corps process on the quality of planning; and there are no constraints on the alternatives to be developed. The task force recommended the following changes for shortening the planning process, which the Corps adopted:

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--> Table 3.4 Cost Analysis of Reconnaissance Studies 1985-1996 Year Reconnaissance Study was Initiated Number of Reconnaissance Studies Average Cost of Study ($1,000) Range of Cost for Studies Initiated ($1,000) Total Cost of Reconnaissance Studies ($1,000) Total Reconnaissance Expenditures That Did Not Result in a Feasibility Study ($1,000) 1985 18 243.3 46-558 4380 3245 1986 28 210.7 43-775 5900 3650 1987 11 396.5 50-1424 3965 2897 1988 77 296.9 50-810 22,859 16,623 1989 35 400.7 100-1178 14,023 8381 1990 42 334.3 50-4380 16,141 7367 1991 71 390.3 20-1320 27,712 17,655 1992 29 349.1 98-1080 10,123 7195 1993 43 456.2 25-1000 19,616 12,705 1994 69 422.3 30-1225 29,138 24,304 1995 34 405.3 100-750 13,780 13,230 1996 38 428.3 55-1000 16,277 -   Source: Corps data.

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--> procedural changes that provide for each feasibility study to be focused and tailored to meet specific needs and objectives; policy changes that, in certain cases, provide for categorical exemptions from requirements to develop and recommend the NED plan; and use of flexible federal-nonfederal cost-sharing of feasibility studies. Two other significant task force recommendations that the Corps has implemented are: elimination of the review by the division engineers; and significant shortening of the reconnaissance study phase. Funds for reconnaissance and feasibility studies are generally not appropriated in the same year. However, the Corps intends to be ready to initiate the feasibility report at the start of the second year, rather than the latter part of the second year or even the third year (which was often previously the case). In addition, Congress introduced the use of the conditional authorization in WRDA '96, which is essentially an extension of the deadline by which a chiefs report must be signed prior to congressional action. It enabled 13 projects with favorable recommendations from district engineers to be authorized, even though they did not have the chiefs reports when WRDA '96 was signed into law on October 12, 1996 (these 13 projects are listed in Appendix C). WRDA '86 included a requirement that feasibility studies would be cost-shared on a 50-50 basis, with a maximum of 50 percent of the nonfederal share to be provided as in-kind services. Since 1986, the Corps has on several occasions increased the feasibility study costs after the signing of the feasibility cost-sharing agreement. Such cost increases can place nonfederal sponsors in an awkward position. For example, the local sponsor may prefer to continue the study but cannot provide its 50 percent of the additional costs in a timely manner. WRDA '96 (Section 203) allows the Corps to finance study cost overruns, given that they do not violate federal laws or change the scope of the study requested by the nonfederal interests. The nonfederal sponsor must agree to repay its share of the excess amount when the project goes to construction (i.e., on the date the PCA is signed). This provision should reduce instances in which feasibility cost overruns delay continuation of studies. Committee Recommendations The committee recommends the Corps implement the following to further shorten the planning process: The Corps should use "seamless funding" between reconnaissance and feasibility, and between feasibility and PED, which may potentially help avoid unnecessary delays. Seamless funding refers to funding available without interruption between two different study/PED phases. For example, once a feasibility

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--> study is complete (and funds exhausted), funds for PED are made available in the same fiscal year. There is no need to wait until the start of the next fiscal year to obtain funds for PED, thus allowing a smooth transition between stages. However, if these funds (from two different pools) are not on hand during the same year, the planning or design process can stall. There is often a six to twelve month gap between completion of the reconnaissance phase and initiation of a feasibility study—even though funds are available immediately in the year following completion of reconnaissance. However, since the abbreviated reconnaissance reports (905(b) analyses) are only a few pages long and take roughly three months to complete, the balance of that fiscal year should be spent preparing the PSP and the FCSA and discussing it with the nonfederal sponsor. This should allow for the cost-sharing agreement to be ready for signing at the start of year following funding of the reconnaissance study. Until fiscal year 1997, moving from feasibility to initiation of PED was essentially seamless once the division engineer's notice was issued. In 1997, it was decided to obtain more nonfederal funds prior to initiating PED. The new policy (although not based on any new law) results in a delay in the initiation of PED until a cost-sharing agreement is consummated. The negotiation of this agreement adds as much as six to nine months to most new PED studies. Once again, seamless federal funding is available, but internal institutional requirements (primarily the processing of cost-sharing agreements) now delay part of the process that worked well in the past. The Corps should strive to reduce any gaps between completion of the district's reconnaissance report and initiation of the feasibility report, as well as between the division engineer's notice and the initiation of PED. The Corps should proceed with PED even while the feasibility report is undergoing final processing at headquarters for authorization. Assuming PED funds are available for a project awaiting authorization (which is often the case), there are opportunities in each budget cycle to receive a federal construction appropriation. For example, the initial construction funds can be included in the president's budget. Processing of the chiefs report should be shortened by 60 days, from six months to four months. The final review by states and agencies (primarily the Department of Interior and EPA) has been shortened in law from 90 days to 30 days. This shorter review period was implemented as part of WRDA '96 (Section 223) and was instrumental in completing the review process and obtaining chiefs reports on several conditional project authorizations contained in WRDA '96 (Section 101(b)). Despite the shorter review mandated for states, the Corps has yet to shorten the processing of Chief of Engineers' reports, thereby delaying the approval process for many water projects. The Corps should provide broader authority for the field (district-level offices) to approve FCSAs when the model FCSA is closely followed. Delays in moving from reconnaissance to the feasibility phase often result from an inability to reach timely agreements with the local sponsor on provisions contained within the FCSA and/or the PSP. WRDA '86 provides that feasibility studies may not be initiated "until appropriate nonfederal interests agree, by contract, to contribute 50%

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--> of the cost for such study during the period of such study. Not more than one-half of such nonfederal contribution may be made by the provision of services, materials, supplies, or other in-kind services necessary to prepare the feasibility report" (from WRDA '86, Section 105). The Corps has developed a model agreement, used in negotiating a final executed agreement prior to the initiation of each feasibility report (except for inland waterway navigation studies). By granting the district-level offices the authority to approve FCSAs that adhere to the model, significant time savings should result. The Corps' district-level offices should strive to complete feasibility reports in two years rather than three, subject to the availability of federal and nonfederal funds. This could be accomplished by starting the feasibility study early in the year that initial funds are apportioned, waiving certain reviews, and implementing the committee's other recommendations. The Corps should continue to seek conditional authorizations in Water Resources Development Acts. As mentioned, conditional authorization allows for the authorization of projects that just miss the final date for the signing of a chiefs report, preventing delays of up to two years (the time projects would normally have to wait for subsequent authorization under the next Water Resources Development Act). It remains to be seen whether the final Washington-level review can be shortened in accord with the streamlining efforts mentioned above. At this point, there are insufficient data upon which to make an assessment. A clearer notion of these initiatives on the length of the planning process will emerge over the next two years. Commentary The expedited reconnaissance stage has resulted in severely constrained analysis in the first stage of the planning process. With only $100,000 and 12 months to complete the study, much of which is devoted to preparing the project study plan, the Corps must rely on numerous assumptions and a screening to determine whether a project should proceed to the feasibility study. Projects that are clearly not feasible will continue to be rejected, but sooner rather than later. Projects that are likely to have favorable recommendations can be quickly moved to the feasibility stage. The expedited process will probably have its most significant impact on those projects for which beneficial and adverse effects are closely balanced. For those projects, two kinds of errors are possible. One is that potentially worthwhile projects could be rejected prematurely because the abbreviated reconnaissance process provides too little time to modify unacceptable initial designs. A second kind of error could occur when an unacceptable project is not rejected in the reconnaissance phase because of a lack of time and resources to support the required analyses. In this case, feasibility studies could cost far more than the added cost of a more complete reconnaissance study.

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--> Too few projects have been subjected to the expedited planning process to draw firm conclusions regarding its effects. If the rate at which feasible projects are found from the pool of feasibility studies does not improve significantly over the historical rate of 27 percent, the process should be reevaluated. Failure to significantly increase that percentage would signify that too many doubtful prospects are being forwarded to the feasibility stage. Toward that goal, the Corps should seek to improve its tracking system for all potential projects for which reconnaissance studies are initiated. The committee reviewed computerized records, which contained dates and costs of reconnaissance and feasibility studies, but did not contain information about recommendations. The committee was left to infer that reconnaissance studies not followed by feasibility studies resulted in no recommended project. No information was available about feasibility study outcomes. Periodic reports (annual, biannual, every five years) showing all planning studies, dates of initiation and completion, costs, recommendations, and current status in authorization and appropriation processes, would be most useful in evaluating Corps planning. These data are available from the Corps, although not in readily retrievable form. From a budgetary standpoint, there may be little to gain by streamlining the planning process. The expedited reconnaissance process should cut planning costs by approximately $300,000 per study, at a rate of approximately 55 studies per year, with a total cost savings of $16.5 million. Balancing that savings is a potential increase in the number of infeasible projects for which decisions are deferred to the feasibility stage. If the average cost of those studies is the same as those over the 1986-1996 period, it would take only a few additional feasibility studies to offset gains from reduced reconnaissance costs. If the cost of feasibility studies can be reduced, then there would be a net gain in efficiency. Three other steps seem desirable. First, the cap on individual projects funded under the Corps' Continuing Authority Program (CAP) should be increased to $10 million. The CAP allows the Secretary of the Army to approve and construct certain types of projects within a "continuing authority" (rather than requiring specific authorization for every Corps project by the Congress). Congress establishes the type of projects that can be built without specific Congressional authorization in the language that creates the authority. The authorities are generally found in one of the omnibus bills, such as the various Water Resource Development Acts. Each continuing authority program has a separate authorization, a spending limit, and a budget. Examples of continuing authority programs include: Section 204: Beneficial Uses of Dredged Material Section 205: Flood Damage Reduction Section 206: Aquatic Ecosystem Restoration Section 1135: Environmental Improvement Although selection of the spending cap within the CAP is arbitrary, the committee believes that the current limit of $5 million is too low. As these continuing authority programs allow the Secretary of the Army to approve certain types of projects, rather than requiring a specific project authorization by Congress, they can significantly reduce delays due to authorization details and help streamline

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--> project planning and implementation. Congress may wish to control the amount of spending under that authority, but the more appropriate way to do that is through the budget process, not a review of small individual projects. Second, Congress should consider seamless funding of projects, assuring that funds are immediately available to begin the PED process as the first step in construction following a favorable feasibility study outcome. Third, the lag time between the feasibility study and initiation of the PED processes should be eliminated if the nonfederal partner agrees to share the costs of preconstruction, engineering, and design. Either seamless funding or some other mechanism could be used to reduce the lag time from feasibility to construction. Under present policy, PED cannot be initiated until a cost-sharing agreement for construction has been signed. As long as a nonfederal sponsor is willing to guarantee payment for its share of PED activities, the process need not be delayed until a complete cost-sharing agreement is signed by both parties. A basic question remains unanswered, however: Does the Corps process take longer and cost more than similar projects that do not involve federal cost sharing? Concerns expressed about inefficiencies in the Corps processes are similar to those involving all water projects, as well as nearly any other development project. There is no readily available set of data by which such projects can be compared with cost-shared Corps projects. However, it is not uncommon for public water supply projects financed solely by local governments to take eight years to be completed. Any project undertaken by a public agency involves developing a level of consensus sufficient to gain the sponsor's approval. It also involves acquisition of necessary lands, easements, and other property rights. Project financing must also be secured. All such projects must obtain a variety of state and federal permits that trigger provisions of the National Environmental Policy Act. Although these processes are subject to inefficiencies, they may very well take as long or longer than Corps cost-sharing projects. Any public organization that believes it can or should move from identification of the need for a project, to design and construction within a four-year period, is either considering a simple project with few complications or is overly optimistic. The key planning guidance documents for the Corps—the P&G and the "Guidance for Conducting Civil Works Planning Studies" (ER-1105-2-100)—have become outdated (although the Corps is currently updating ER 1105-2-100) and should be revised to reflect contemporary analytical techniques and planning concepts. Revising these documents, however, will not result in further significant reductions in the length of the Corps planning process. The recommendations offered in this chapter would allow the Corps to further reduce the time required in its two-step planning process without significantly reducing planning quality. Beyond the committee's recommendations, there are few other steps the Corps could implement that would not compromise the integrity of that process. It bears repeating that further cuts in the time and cost of the planning process do not necessarily result in a better process. The Corps' planning procedures have evolved with changes in national water policy and advancements in economic and engineering techniques. However,

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--> as Chapter 4 describes, the nation's water policies and practices do not always square with widely-accepted principles of water resources planning.