The U.S. Army Corps of Engineers for Civil Works has released, for public comment, long-awaited guidance that officials say provides a framework for the agency to consider a broader range of benefits than just cost and economic development for proposed water resource projects.
The Corps’ Agency Specific Procedures, proposed earlier this month in the Federal Register, provides guidance on how to implement principles, requirements and guidelines for water resource investments, establishing what the agency can and cannot do in evaluating its approaches and recommendations for related projects.
Known as PR&G and dating to 1983, the guidance was updated in 2014. But U.S. lawmakers included riders in annual appropriations bills that restricted the Corps from taking the next step toward implementing the guidance beginning in 2012, even before the update was completed. As a result, the agency could not move forward with developing specific procedures to implement the updated guidance until the Water Resources Development Act in 2020 included language directing it to develop the procedures.
“Through these procedures, we will continue our efforts to modernize civil works programs by maximizing public benefits and ensuring recommended projects achieve their water management objectives and better reflect community needs and priorities,” said Michael Connor, Assistant Army Secretary for Civil Works, in a statement. “We are committed to integrating economic, environmental and social benefits into our planning and improving the Corps’ ability to build resilience in a broad range of communities, including rural, tribal, and low-income areas.”
According to Todd Bridges, who founded the Corps Engineering with Nature program in 2010, the new procedures could potentially bring big changes to the way the agency conducts feasibility studies.
Corps engineers will no longer be hamstrung in their ability to value approaches with benefits that are harder to quantify numerically but which still bring broad benefits to the environment and communities, Bridges, now a professor at the University of Georgia Institute for Resilient Infrastructure Systems, told ENR.
“I think this opens the door for all types of approaches and options,” including nature-based and environmental justice solutions, he said.
Doug Lamont, a former Corps Civil Works program official who now is a senior advisor at environmental consulting firm Dawson & Associates, said the procedures will give Corps engineers more latitude in choosing nonstructural solutions to problems.
He said the most cost-effective solution might be to build a flood wall in a community, but if it would bisect an area that functions as a cohesive community, a nonstructural solution such as setback levees and wetlands might be a better solution.
The National Waterways Conference—which represents industry and contractor groups involved in water resource projects, including port and dredging contractors, contractor associations, energy companies and others—is still reviewing the proposal but is initially “encouraged” by the Corps procedures’ emphasis on considering multiple benefits on water resource projects, said Julie Ufner, president and CEO. “However, we want to be sure the approach and methodology are consistent and predictable for nonfederal sponsors who invest significant amounts of time and money in these essential projects,” she said.
Individual Corps districts have their own approaches and practices that may not completely harmonize with priorities of Corps headquarters, according to Melissa Samet, legal director for water resources and coasts at the National Wildlife Federation. “I think some Corps districts have viewed themselves as being limited in the approaches they can use and the ways that they value things. Hopefully, this [ASP] will help change that view.”
More guidance and training are essential to ensure the procedures are adopted and properly implemented, Samet said. “It’s a big ship to turn, but I do think that we need to see a change across the board at the agency,” She added.
The Corps will accept public comment on the proposal through April 15.
