New Directions in Water Resources Planning for the U.S. Army Corps of Engineers (1999)

Primarily in response to complaints from its project cosponsors, the U.S. Army Corps of Engineers requested the Water Science and Technology Board of the National Research Council to conduct this study. The committee was asked to provide advice on the following:

1. Assess the Corps' structured project planning process to determine if all steps are necessary and if the process can be streamlined. Is the Corps' planning effort reasonable, given the level of investment?
2. Consider the necessity for a major evaluation of the Economic and Environmental Principles and Guidelines for Water and Related Land Resources Implementation Studies. Can this process be streamlined without undue harm to land and water resources?
3. Consider how the cost-sharing requirements of the 1986 Water Resources Development Act have affected the potential development of new Corps water projects. This should address the number and size of projects, as well as effects on study duration and timing.
4. Consider how the requirement to include risk and uncertainty analysis has affected project planning, development, and the range of alternatives considered.

5. The Corps has taken several steps during the past two to three years to help streamline its planning processes. The committee has identified additional steps which can help the Corps further reduce planning time. However, the Corps project planning procedures are generally sound and not excessively lengthy when compared to private sector water planning studies.

   The committee was also requested to consider whether the Principles and Guidelines required major review. The P&G are central to Corps planning and have been incorporated in the Corps' primary planning document, "Guidance for Conducting Civil Works Planning Studies" (ER 1105-2-100). The P&G have not been updated since they were adopted in 1983. While the P&G have not changed, water resource programs and analytical techniques have evolved considerably over the past 15 years. The Corps' current work program includes a complex mixture of structural and nonstructural elements designed to reduce damages from floods, as well as restore the natural structure and processes of aquatic ecosystems in others. These new missions and their ramifications were not anticipated when the P&G were developed.

   Though the P&G have been valuable, they are in need of modernization. But

if the need for modernization of the P&G is clear, the procedures for accomplishing their modification are not, because the WRC is dormant and there are no plans to reestablish it. The administration should take whatever action necessary to charge someone to carefully evaluate the P&G, make updates and revisions, and propose a new document. If neither the administration nor Congress soon begins a new interagency effort to update these procedures, the Corps should take it upon itself to draft new planning procedures that reflect current conditions. The Corps is currently moving in that direction through its draft revisions of the "Guidance for Conducting Civil Works Planning Studies."

The Science Advisory Board of the EPA recently called attention to the fact that no existing federal program systematically addresses the highest categories of ecological risks, such as hydrologic alteration, habitat conversion, turbidity/sedimentation, habitat fragmentation, and introduction of exotic species. The Corps should take the opportunity to revise its planning guidelines to address these issues.

The understanding, modeling, and prediction of ecological system behavior is complex and time-consuming, even more challenging than the Corps' complex hydrologic modeling studies. To build on its existing expertise and extend it into these new areas, the Corps must continue to strengthen its knowledge in the biological and ecological sciences and attempt to quantify ecological benefits and costs as part of its modeling processes. Beyond monetized ecological values, the Corps should consider noneconomic ecosystem values and services, such as biodiversity and natural carbon storage, in considering water project alternatives. In revising its planning processes, the Corps should reconsider WRC standards and analytical techniques that disfavored nonstructural solutions to water resource problems. The best modem engineering practices usually lead to projects that include both structural and nonstructural components, and the planning rules should not bias the selection of the mixture.

To manage the nation's water resources effectively, the Corps must evaluate its larger projects from a regional perspective. For example, flood damage reduction projects that merely pass floods downstream do not serve the national interest, nor does shoreline protection that increases erosion elsewhere. The Corps should use the watershed or river basin, the estuarial region, and coastal unit as the basic spatial units in planning to account for the cumulative effects of water projects in the same hydrologic system.

The expansion of scientific knowledge has caused increased planning time not only for the Corps, but for every other government agency and the private sector. Similarly, increasingly complex analytical procedures, such as the Corps risk and uncertainty analyses, further lengthen the process. Our understanding of the world's complexity will only increase, and time saved through improved communications and more streamlined procedures can counteract but not reverse this trend. Expectations of reduced planning times should thus be modest.

Local cosponsors occasionally do not provide the Corps with adequate information about local stakeholder interests and desires, contributing to delays in planning. The committee thus recommends that local sponsors be required to provide basic economic and demographic data to the Corps, as well as provide assurances of local stakeholder involvement, before asking the Corps to undertake water project planning. The local sponsor should also be required to identify the

alternatives proposed by all interested stakeholders and provide their supporting rationale before the Corps undertakes a reconnaissance study. Similarly, the Corps can increase the speed and cost-effectiveness of planning by providing more complete guidance to local sponsors on information to include when submitting a proposal for a reconnaissance study. As this report has explained, however, further reductions in the time and cost of Corps planning studies do not necessarily result in a better planning process. The Corps planning process takes as long as it does, at least in part, due to federal, state, and local regulations, including local sponsor input, and the Corps' own stringent requirements.

The committee's recommendations are divided into four categories: (1) internal organization; (2) external issues; (3) relations with local sponsors; and (4) analytical methodology.

These recommendations can be implemented internally by the Corps.

1. The Corps should emphasize a basinwide or regional perspective in all major planning studies in order to fully account for all impacts in the relevant river systems.
2. The Corps should eliminate needless gaps in the project planning process. For example, the negotiated PED cost-sharing agreement should be completed at the time the division engineer's report is released to Corps headquarters.
3. The Corps should include a monitoring and evaluation component in the planning of all water resource projects. The project should be charged with the cost of the monitoring component to the extent it is needed to manage the project adaptively.
4. The Corps should allow for the omission of analysis of expensive alternatives and levels or stages of review for small projects on which a consensus exists. Regulations need not impose the same procedural steps for all sizes of project.
5. The Corps or an independent research group should conduct a study to determine whether any systematic biases exist against the Corps' nonstructural flood damage reduction projects.

6. External Issues

   These recommendations require action by Congress or coordination with agencies other than the Corps.

   1. The committee recommends that the P&G be thoroughly reviewed and modernized. As discussed, the committee found several reasons why the P&G need to be updated, including: (a) a need to move away from strict adherence to the NED account; (b) the Corps' environmental improvement and restoration programs were

• all enacted after the P&G were formulated; (c) a need to update analytical techniques; and (d) the need to consistently consider benefits of flood damages avoided in all nonstructural flood damage reduction projects.
  
  

  Procedural details over which agency will refine the P&G should not be allowed to delay this action. Much of the excellent work that went into their conceptualization can be retained in new guidelines that reflect changing Corps (and other federal, water-related agencies) missions and advances in scientific and engineering knowledge.

• Unless the administration or Congress takes some other action to review and modify the P&G, the Corps should initiate a comprehensive rule-making process to adopt its own planning procedures and guidelines, providing maximum opportunities for input from other public agencies and the private and nonprofit sectors.
• The Corps should be given more extensive authorization by Congress to formally undertake large scale regional planning activities which include multiple projects. These activities will allow the Corps to budget resources and complete projects in a more efficient and timely manner.
• The committee noted excessive fragmentation of responsibilities for federal water planning, significant changes in the programs and capabilities across the federal water apparatus, a lack of a comprehensive and up-to-date overview of the nation's significant water problems, and an erosion of basinwide perspectives and coordination. An executive-level group to formulate national water policy and to coordinate and promote interagency collaboration should thus be created. Initial tasks for this group could include coordinating information and analytical techniques across federal water planning agencies, as well as revising the P&G. The committee recommends that the Congress consider placing this body within the Office of Science and Technology Policy (OSTP). This recommendation is not intended to create another large government agency, but rather to create a means to help coordinate national water policies.
• Congress should increase the cap on individual projects within continuing authority programs to $10 million and raise the cap on the entire program to a corresponding level. Many of these caps have not been increased to reflect the inflation of construction costs.
• The Corps should continue its research on prospective global warming, climate change, and changes in sea-level, and attendant hydrologic, economic, and environmental impacts.

Local sponsors and other stakeholders should be consulted before these recommendations are implemented.

1. As unorganized local sponsors can contribute to delays in the planning process, local sponsors should be required to consult with affected stakeholder groups to identify their desires, concerns, and the range of desired alternatives before the Corps undertakes a reconnaissance study. Local sponsors should also be required

• to provide the Corps with basic economic and demographic data relevant to planning.
• The Corps should revisit the current application of cost-sharing criteria based on the ability to pay and should devise more workable approaches. The Corps should review its current and recent projects to examine how local sponsors' ability-to-pay has been affected by cost-sharing criteria. Special attention should be paid to identifying any systematic problems that may limit the Corps' ability to help the poor address water-related problems, especially floods.
• The Corps should seek to reduce delays between the reconnaissance and subsequent phases of a project. If it appears that a reconnaissance study will have a favorable outcome, the Corps should immediately begin to collaborate with the local sponsor on the various steps needed to launch the next phases of the project. Any time that will be wasted when a reconnaissance study develops last-minute problems will be outweighed by many months of time saved on most projects.

1. Where there is a legislative or regulatory directive for an environmental improvement or restoration project, the evaluation should include, at a minimum, cost-effectiveness analysis. Where possible, the project evaluation should include benefit-cost analysis.
2. Analytical methods should be continually updated and improved to account correctly and adequately for all categories of benefits and costs. For example, avoidance of costly disaster relief assistance by relocating residents out of flood-prone areas should be considered in evaluating the benefits of all nonstructural flood damage reduction projects. A study which seeks to identify biases which may exist against the Corps' nonstructural flood damage reduction projects should be commissioned and conducted.
3. Closer examination should be given to the calculation of the monetary benefits and costs of environmental restoration. Work should proceed toward the development of a standard set of accounting units and easily applied computer models to quantify benefits and costs for all Corps projects. It should be recognized that but for the larger projects, it may be infeasible, due to time and financial constraints, to undertake major original studies. It will, however, be necessary for the Corps to undertake high quality original research which is now lacking in many areas in order to support the development of reliable benefit-transfer models.
4. The Corps should estimate the time required to conduct risk and uncertainty analysis of economic and hydraulic parameters in its flood damage reduction, navigation, and shoreline protection projects. If significant time and resources are required, the Corps should consider limiting its treatment of risk and uncertainty to sensitivity analysis. While historical records are commonly available to support assignment of probabilities to hydrologic events, data to support probability analysis of economic and hydraulic parameters in particular settings are limited. Furthermore, sensitivity analysis combined with expert judgment about probable ranges of parameters may be sufficient to support decision making in most cases.
5. The Corps should initiate development of techniques that give explicit

• treatment of uncertainty in adaptive environmental management projects. Appropriate techniques should recognize the sequential decision making process inherent in projects of this kind, providing guidance as to whether such projects should be initiated and whether they should be continued or terminated when subsequent decision points are reached.