National Research Council “216” Studies: Corps of Engineers Water Resources Project Planning
In Section 216 of the Water Resources Development Act (WRDA) of 2000, the U.S. Congress requested The National Academies1 to review the Corps’ methods of project review and analysis (see Appendix A for the exact Section 216 language). In response to this request the Water Science and Technology Board of the National Research Council (NRC), in collaboration with the NRC’s Ocean Studies Board, appointed four study committees: (1) peer review; (2) adaptive management; (3) analytical methods; and (4) river basin and coastal systems planning. A coordinating committee was also convened to follow the committees’ progress and to issue its own report. This chapter reviews common themes identified in those reports and then summarizes conclusions and recommendations from each of the five reports.
COMMON THEMES WITHIN THE 216 STUDIES
Several common themes regarding Corps of Engineers planning and analytical processes emerged from the five 216 study reports. Given the prominence of the 216 studies within this report’s statement of task, key findings and recommendations from those studies are presented in this chapter. This summary is based on the committee’s reading of the 216 study reports and is provided as a convenience to the reader who may not be familiar with the reports from the
various 216 study panels, as well as important background information for discussion in Chapter 3. This chapter only summarizes the 216 reports and does not reflect additional critique or commentary from this NRC committee.
The following were key findings from the 216 study panel reports:
The value of more thorough analyses and peer review during early stages of Corps planning studies. Recommendations in this area included the occasional need for more resources in Corps reconnaissance studies and the potential value of including stakeholder groups in a planning study’s initial stages.
The need for increased postconstruction evaluations, or ex post studies, of Corps projects. The reports notes that such retrospective assessments are integral to sound water planning in general and to adaptive management in particular.
The need for a greater degree of centralization and streamlining of Corps planning programs and studies. The Corps is highly decentralized, with dozens of district offices spread across the United States. This arrangement may have some limitations with regard to more complex Corps planning studies, and it may inhibit the sharing of information and learning from experience throughout the agency. The reports also observe that Corps planning reports do not always clearly convey key assumptions, methods, costs and benefits, environmental problems and concerns, and conflicts and differences of opinion.
The Corps and other U.S. federal water resources management agencies today rely on a diverse collection of policies, regulations, and case law that constitute the de facto national water policy. Many of these laws have only limited relevance to contemporary water resources needs and in some cases are not fully consistent with more recent laws. This situation occasionally results in confusion (or worse, conflict) between federal agencies. All the study panels discussed these issues, with their recommendations sometimes framed differently. For example, one panel (Analytical Methods) recommended the assignment of interagency coordination responsibilities to a governmental body. Other panels (Adaptive Management, and River Basins and Coastal Systems) called for clarification from the administration and Congress in sorting out inconsistencies within the de facto body of national water policy. The Coordinating Committee recommended a slightly different approach in reconciling these types of inconsistencies, calling for the creation of a process to elevate interagency conflicts to higher authority.
The need to consider implications of study cost sharing (the contribution of a local sponsor to a Corps civil works project). All 216 study panels discussed cost-sharing arrangements for Corps projects, generally noting that increased cost-sharing requirements resulted in a complex mix of positive and negative outcomes. Further investigations into and advice on this topic were beyond the scope and resources of the study panels, but the panels concluded that Congress and the Corps should investigate the full implications of cost-sharing policies.
The need to create more flexible management processes and strategies. These discussions manifested themselves as comments regarding postconstruction evaluations, adaptive management, and relations with federal agencies and other stakeholders. A recommended overall management strategy, consistent with current budgetary, infrastructure, and social realities, was characterized by the Coordinating Committee report as portfolio planning. The portfolio metaphor refers to the collection of assets that the Corps operates or has responsibility to operate or maintain. These assets include the Corps’ physical water management infrastructure—including levees, locks, dams, navigation channels, floodwalls, and ice control structures—and the hydrologic (water) and geomorphic (sediment) resources controlled by that infrastructure.
Congress was particularly interested in the process by which the Corps reviews its planning studies. This subject was granted priority within the “216 studies,” with one of the study committees addressing the topic in detail (NRC, 2002). Increasing concerns in recent years regarding environmental impacts, economic evaluations, political pressures, and shifting water management paradigms have led to increased criticism of Corps of Engineers planning studies and projects. The complexity and sophistication of most large water resources planning studies suggest the value and importance of some degree of independent review. There is a strong correlation between the independence of reviewers—in terms of knowledge, association with a project, and organizational affiliation—and the credibility, both real and perceived, of external review. A carefully designed review process for Corps planning studies can increase credibility, improve scientific and technical applications, and help ensure planning studies of the highest quality. The Peer Review Committee report recommends the creation of an internal administrative group within the Corps to coordinate all reviews of Corps planning studies.
Whatever type of review process is implemented within the Corps, the report from the Peer Review Committee recommends that the role of review panels should be to identify, evaluate, explain, and comment on key assumptions that underlie technical, economic, and environmental analysis. Review committees should highlight areas of disagreement and controversies to be resolved by the administration and Congress. Review committees also should be free to comment on topics they deem relevant to decision makers, leaving it to the recipient of the review to decide whether those issues constitute technical or policy issues. Review committees, however, should not be requested to provide a final judgment on whether a particular alternative from a planning study should be implemented.
The Peer Review Committee report recommends that the Corps’ more expensive, complex, and controversial planning studies be reviewed by independent, external experts. These independent review teams should not include Corps staff, nor should panelists be selected by the Corps. These independent reviews should be overseen by an organization independent of the Corps. Examples of such independent organizations include professional scientific and engineering societies, the National Academy of Public Administration, the National Research Council, and independent federal oversight groups similar to the Department of Energy’s Defense Nuclear Facility Safety Board. Internal reviews are appropriate for less complex and less costly planning studies, and for those that involve lower levels of risk. The Peer Review Committee report also recommends that internal reviews be conducted by review committees that include a balance of Corps staff and external experts.
The Peer Review Committee report recommends that results of a review should be presented to the Chief of Engineers well before a final decision is made on a planning study. Reports from review committees should be public documents and should appear in water resources project planning studies submitted to Congress. The review’s primary client—usually the Chief of Engineers—should respond in writing to each key point contained in a review. The chief should either agree with the point and explain how it will be incorporated in the study, or rebut the comment and explain why it is being rejected.
Timing, continuity, and costs of review are key considerations. Corps of Engineers planning studies are conducted in two phases—a reconnaissance phase and a feasibility phase—typically lasting one to two years. The point at which the review should be initiated is not always clear because much depends on a study’s complexity and duration. If review is initiated early in the study, however, findings and recommendations can be more easily incorporated into the feasibility study. For more controversial studies the report recommends that reviews are best initiated early in the feasibility phase, or even earlier, during the reconnaissance phase. Multiple reviews conducted at several stages of planning studies may also have value, particularly in more controversial and challenging studies, some of which may require 10 years or more to complete.
The traditional focus of the Corps of Engineers’ civil works program for water resources has been construction-oriented. This focus has shifted over time, however, as federal budgets for new water projects have declined, as public support for new water projects has waned, and as many of the best construction sites for new projects have been developed. In addition, the Corps, along with
many other U.S. economic, business, and management entities, is seeking to augment traditional, capital-intensive, construction-based approaches with strategies aimed at producing greater benefits and flexibility from existing structures and systems. The Corps today finds itself in a setting in which it must pay increasing attention to shifting water project goals, possible operational changes, and the use of feedback and lessons from project outcomes.
As the report from the Adaptive Management Committee points out, the concept of adaptive management gained attention during the late twentieth century as an approach that could help increase natural resources management flexibility and project and system benefits. Adaptive management calls for policies that can be adjusted as new information is gathered and discovered. It calls for the monitoring of outcomes to advance scientific understanding and to help adjust policies or operations within an iterative learning and management process. Adaptive management recognizes inherent variability and dynamics in natural and social systems. It calls for ongoing reassessment of environmental, social, and economic goals in connection with stakeholder collaboration. The true measure of adaptive management is how well it helps meet environmental, social, and economic goals, and the extent to which it increases scientific knowledge and promotes collaboration among stakeholders.
The Adaptive Management Committee report also notes that adaptive management is an evolving concept, and its implementation represents a challenge for a construction- and operations-oriented agency like the Corps of Engineers. Key elements of adaptive management are the establishment of a process for reviewing and revisiting management objectives, a range of management options, monitoring and evaluating outcomes, a framework for incorporating new knowledge (economic, engineering, ecological) into management decisions, and stakeholder collaboration. Adaptive management provides a means of responding to changing conditions through revised management actions, while seeking to avoid costly or irreparable mistakes and unintended consequences. It allows for operational changes that respond to changing social preferences and new scientific information.
The Adaptive Management Committee report also offers some cautionary advice, noting that despite its promise and potential, formal adaptive management practices and programs have not been widely applied. Its successful implementation will thus entail not only patience but also a degree of willingness among stakeholders to find common ground. Stakeholders must agree on at least some fundamentals within adaptive management, such as the key scientific or other questions that they would like to pursue using adaptive strategies. Absent any degree of cooperation, a formal adaptive management program may not be viable.
The report recommends that the Corps implement adaptive management at different scales and in different settings, track progress, and aim to learn from successes and setbacks. There is a spectrum of possible adaptive management approaches.
More passive programs focus on monitoring the results of management actions, while more active programs design specific actions to test multiple models of system behavior. The report recommends that the Corps consider the full spectrum of possible adaptive management approaches, and begin developing guidance regarding suitable approaches in different circumstances. Adaptive management strategies may be particularly useful in large, complex ecosystem restoration projects, which often entail high degrees of risk and uncertainty, along with multiple objectives and phases. The Corps was advised to also promote adaptive strategies based on lessons learned from previous, smaller-scale efforts. Although adaptive management strategies are closely linked with natural resources management projects, they can be used in other systems as well. The Corps should consider ways that adaptive management or similar strategies could be applied to its navigation and flood risk management programs, as well as to ecological restoration. Finally, the report recommends that a Center for Adaptive Management be created within the Corps. This center should start as a carefully planned, modest effort for an initial five-year period and its progress should be periodically reviewed.
Adaptive management programs should systematically incorporate means for stakeholder collaboration into planning and management decisions. The monitoring of physical, biological, and economic aspects of natural systems often poses substantial water resources management challenges. The ambiguities that often attend the monitoring of complex ecosystems can hinder adaptive management’s cycle of action, observation, evaluation, learning, and new action. Independent expert review can identify inadequacies in modeling, monitoring, and assessment and can help resolve scientific disputes, and therefore should be part of adaptive management programs.
The quality and credibility of Corps planning studies have been criticized by some groups (e.g., NWF and Taxpayers for Common Sense, 2004). If these criticisms are valid, explanations for the problems could include limited resources for the development and applications of sophisticated analytical methods and models, increasing competition for engineering talent from the private sector, and a lack of clarity of planning objectives and policy direction. The 216 Analytical Methods Committee report (NRC, 2004d) reviewed Corps planning procedures as embodied within the federal Principles and Guidelines for Water and Related Land Resources Implementation Studies (“Principles and Guidelines,” or simply, P&G; WRC, 1983) and within the Corps’ own Planning Guidance Notebook (USACE, 2000).
The Analytical Methods Committee report finds that the Corps is hindered in its ability to define clear management directives because of inconsistencies in
the large body of de facto national water policy that guides the agency. To provide clearer direction to the Corps the report recommended that the administration and the Congress, in cooperation with the states, should reconcile inconsistencies within this “policy.” The demise of the federal Water Resources Council in the early 1980s resulted in the loss of a key forum for interagency collaboration on water policy and management issues. As a result, administration-level coordination has been much less frequent, and today there is an abundance of interagency conflicts and loose ends. The report thus also recommends that a government entity be charged with coordinating water policies and activities among the administration, the Congress, the states, and federal agencies with water resources management responsibilities.
The water resources programs of the Corps (along with three other federal agencies) fall within the scope of the planning guidelines set forth in the federal Principles and Guidelines. This document, issued by the former federal Water Resources Council, has not been updated for over 20 years. Over this period there have been many changes and advances in planning and analytical techniques, such as valuation techniques, adaptive management, and shifting views of stakeholder participation. The report thus recommends that the federal Principles and Guidelines be revised to better reflect contemporary management paradigms, analytical methods, legislative directives, and social, economic, and political realities. Regardless of whether the administration chooses to revise the Principles and Guidelines, the report recommended that the Corps draft a revision to its Planning Guidance Notebook that is consistent with the Analytical Methods report and present it to the administration.
When the Flood Control Act of 1936 was signed into law, conventional wisdom dictated that a proposed water resources project would be considered viable only if its projected benefits exceeded the projected costs. Sound benefit-cost analysis is still recognized as vital to good decision making; however, it is not regarded as the sole criterion regarding public policy or investment decisions, as these analyses may contain substantial uncertainties and may not adequately reflect relevant, difficult–to-measure (often qualitative) factors, such as stakeholder opinions or nonmarket values. The report thus concludes that benefit-cost analysis should not be used as the sole decision criterion in judging whether a proposed water resources planning or management alternative should be approved.
Corps planning studies routinely are hundreds to thousands of pages in length. Crucial assumptions, alternatives considered, models and datasets employed, and other factors are thus often difficult to understand clearly. The Analytical Methods report concludes that a summary document identifying key objectives, primary environmental and social issues, key assumptions and alternatives considered, trade-offs, and benefits and costs (monetized and nonmonetized), would facilitate better understanding among all parties involved in a planning study. This summary should
be presented with a consistent format and should be a standard component of all Corps planning studies.
Periodic monitoring of completed projects should be a routine part of project planning and management. Congress should provide resources to conduct retrospective, or ex post, evaluations of water projects and systems, as these types of studies are essential to sound water resources planning. These retrospective reviews can serve as effective means for understanding how demands for project services have changed over time or how closely a project has come to meeting its stated goals. The limited number of reviews of Corps projects may represent a missed opportunity to evaluate strengths and weaknesses of planning methods and how project operations have or have not changed to meet changing conditions.
RIVER BASINS AND COASTAL SYSTEMS PLANNING
Water resources project objectives have broadened to include increased emphasis on environmental (e.g., ecosystem health, biodiversity) and social (e.g., risk exposure, economic development, recreation) objectives, which has increased the complexity of water project planning. To meet these demands the Corps is being asked to undertake integrated water project planning, adopt a watershed or regional approach, and include ecosystem perspectives in its planning processes. Integrated water resources planning is endorsed within the scientific and engineering communities and is supported by Corps policy and statements from Corps leaders. Integrated water resource planning at the river basin and coastal system scale provides a framework within which trade-offs among competing objectives can be evaluated; multiple stressors, unintended consequences, and cumulative effects can be identified; and a more complete assessment of the costs and benefits of a project can be examined in a context that incorporates stakeholder interests. Such efforts represent a challenge not only because of the complexity of the contemporary planning environment, but also because of the complex mix of legislation, congressional committee language, administrative rulings, and legal precedent that defines the nation’s water policies. The River Basins and Coastal Systems Committee report concludes that the clear policy guidance and consistent funding and authority necessary to support integrated planning at the scale of river basins and coastal systems currently does not exist.
The River Basins and Coastal Systems Committee report also finds that a lack of consistent national policy guidance, together with pressures to quickly develop water projects with well-defined local benefits, has hampered the Corps’ ability to consistently plan water resources projects within a broader and integrated systems context. Furthermore, the report notes that efforts to more fully
integrate water resources planning across spatial scales must compete with pressures to focus on local projects advocated by local interests and their congressional representatives.
Effective water resources planning requires guidance on evaluating incommensurate objectives and determining the appropriate time and space scales of the study. As noted above, the P&G has not been substantially revised for twenty years, and it is weighted toward benefit-cost analyses that are more appropriate for more traditional, single-purpose water resources projects than for complex, multi-objective water and ecosystem restoration projects. Planning guidance should be updated to provide more balanced and complete information on conducting integrated water systems planning within river basins and coastal systems.
Uncertainty is an inherent part of the management of all natural systems. In the face of uncertainty, water resource planning and management require an adaptive approach in which management actions are framed as experiments that are used, in part, to inform and enhance future decisions. In this context it is necessary to identify key elements of the system whose monitoring will indicate the success of the project in meeting its objectives. Consistent monitoring provides the opportunity to change project features in ways that can correct for unintended or inferior results. Ongoing project performance evaluations are important when dealing with increasingly complex and highly interactive systems. The report also concludes that project evaluation should be a routine component of all water project operations, and its costs should be shared with the local sponsor. Because the complexity and potential consequences will vary from project to project, current cost limits on project evaluations should be replaced with a system in which the scope, tasks, standards, and costs of project planning and evaluation are determined on a case-by-case basis within a feasibility study.
An improved water resources planning environment will require the support and cooperation of Congress, the executive branch, and the U.S. citizenry. General policy guidance mandating watershed, regional, and ecosystem analysis is clear and publicly supported by Corps leadership. Political support for true watershed or coastal systems planning, however, has been neither consistent nor strong enough to overcome the challenges of implementing this sophisticated concept. The report thus concludes that changes in planning guidance and Corps institutional procedures can allow for more effective and consistent applications of integrated water resources planning and environmental stewardship in river basins and coastal systems.
The Coordinating Committee report notes that the Corps of Engineers today
is in a position in which it must maintain and operate an extensive water resources infrastructure that must serve both traditional purposes (e.g., navigation) and a new ecosystem restoration mission. Management of this existing infrastructure of dams, waterways and canals, ports, harbors, levees, and hydropower facilities is important because Corps of Engineers structures control a large portion of hydrologic and geomorphic processes in the nation’s major river systems and along its coastlines. Efficient infrastructure management is also important because construction spending on federal water projects has declined over the past few decades, thereby increasing the importance of better management of existing facilities. The Coordinating Committee report thus recommends that the Corps center its planning activities around a concept of “portfolio planning.”
The Coordinating Committee report notes that the term “portfolio” is used in Corps planning documents (and elsewhere), and that its use in this setting entails the consideration of all Corps of Engineers assets in managing water and related resources. These assets include (a) physical infrastructure, such as locks, dams, levees, and navigation channels; and (b) the water and sediment resources controlled by that infrastructure (e.g., water and sediments that could be released in dam flows in order to rejuvenate wetlands and floodplains). Portfolio planning includes management of existing infrastructure, the addition of new infrastructure, and—where warranted—removal or decommissioning of infrastructure. It entails evaluation of new investments in the context of existing infrastructure and its operations. As the Coordinating Committee report states, “Portfolio planning does not mean that the Corps program will no longer serve traditional navigation and flood risk management needs, but it does mean that the needs can no longer primarily determine how past project investments are operated and new project investments evaluated” (NRC, 2004f).
The Coordinating Committee report also provides advice on focusing Corps of Engineers program areas and mission. In particular, it recommended that the Corps focus its primary environmental mission on the restoration of hydrologic and geomorphic processes in large river and coastal ecosystems. The Corps of Engineers has made ecosystem restoration a program area on par with its traditional flood and navigation programs. The Coordinating Committee report notes that the Corps’ emphasis within the broad field of restoration, however, is currently not well defined and could conceivably cover many different dimensions, including species reintroduction. The recommendation to focus on hydrologic and geomorphic processes was offered for several reasons. One is that hydrology and geomorphology are traditional fields of Corps of Engineers emphasis and expertise. Another is that there are abundant opportunities for the Corps in these realms. Finally, a focus on these components of water management will help delineate the Corps’ responsibilities with regard to other federal agencies that are also working in ecosystem restoration (e.g., the U.S. Fish and Wildlife Service and the U.S. Geological Survey).
The Coordinating Committee report recommends that a new study authority be enacted for the Corps of Engineers. It notes that many Corps planning studies today are conducted not for the construction of new infrastructure but to rehabilitate existing infrastructure or to create new operations schemes. The Corps possesses authorities that allow it to conduct planning studies regarding project operations, for example. The two most commonly used continuing authorities are from the 1970 Flood Control Act and the 1986 Water Resources Development Act. The Upper Mississippi River-Illinois Waterway feasibility study was conducted pursuant to the 1970 Flood Control Act. These existing authorities, however, were not designed to help orient the agency’s planning processes and priorities toward managing existing infrastructure, and the report concludes that they thus are insufficient for moving the Corps toward the planning portfolio paradigm. The report lists several principles that should be part of the new study authority (NRC, 2004f, p. 6-7).
The portfolio planning concept, a focus on hydrology and geomorphology within ecosystem restoration, and a new planning authority are the first-order recommendations from the Coordinating Committee report. The report also lists several other recommendations that support these first three recommendations. These recommendations are in the areas of planning expertise, resolving interagency differences, regional assessments, use of computer-aided decision making, content of a Chief’s Report, reconnaissance-feasibility study distinctions, and backlogged projects that have been authorized but for which funds have not been appropriated.
216 STUDY REPORTS SUMMARY
The U.S. Army Corps of Engineers is one of the nation’s oldest and most recognized federal agencies, with a long history of national service. Today, however, as national and global economic, environmental, and trade priorities shift, the Corps is experiencing considerable organizational, technical, and budgetary challenges, a well as challenges to its authority and capabilities. The 216 study committees considered this larger context of Corps of Engineers project planning, and their reports were offered in the spirit of helping the Corps best meet the nation’s emerging water resources and related needs.
By recommending procedures aimed at increasing the Corps’ decision-making flexibility, the 216 study reports may provide some impetus toward helping the Corps move into a new national water management era. The reports recommend an increased emphasis on postconstruction monitoring and subsequent operational adjustments. This recommendation was made in recognition of the inevitable uncertainties and surprises associated with Corps projects, as well as shifting social
preferences for the benefits of civil works projects.
The administration, Congress, and the states need to play more active roles in defining the Corps’ missions and programs. This is necessary to coordinate the Corps’ efforts with other agencies, to provide clearer direction within a complex and sometimes inconsistent body of de facto water policy, to provide adequate resources for the Corps to make necessary transitions and changes, and to forward conflicts that the Corps and other line agencies cannot resolve to higher authority. Finally, there is a need for a greater flexibility of Corps management and planning regimes, which includes an increased ability to monitor postconstruction outcomes and make necessary adjustments. This concept is treated in detail in the report from the Adaptive Management Committee, and also is captured in the Coordinating Committee’s portfolio planning metaphor, which describes the broad suite of Corps of Engineers assets—namely, physical infrastructure and the water and sediment resources controlled by that infrastructure.
Few Corps of Engineers planning studies have attracted more attention than the agency’s feasibility study for the Upper Mississippi River-Illinois Waterway. The following chapter builds upon the findings and recommendations presented in the 216 study reports, and comments on the implications of those reports for managing the diverse resources across the Upper Mississippi and Illinois River systems.