Proposed revisions to the Economic and Environmental Principles for Water and Related Land Resource Implementation Studies (the P&G) failed to consider public input and ignored the goals and objectives promoted by Congress in the Water Resources and Development Act of 2007 ( Section 2031), according to comments submitted on behalf of the American Society of Civil Engineers.
“(The U.S. Army Corps of Engineers) USACE’s present inability to quantify, in monetary terms, environmental impacts and the risk to the public almost guarantees that there will be no consensus in the vital project development and authorization stage of large projects because analysis is skewed in favor of pure economic development benefits,” ASCE said.
The proposed P&G take a process that was designed to be consistent and transparent and instead create a mechanism that is ambiguous and unnecessarily complex, places too much emphasis on alternative planning, and needs to have the Principles apply to all agencies involved in such planning, according to comments prepared by the Water Resources Coalition (WRC). WRC comments prepared by ASCE Government Relations Director Brian Pallasch and Marc Giamberadino of the Associated General Contractors, both co-chairmen of the Water Resources Coalition were presented to Larry Prather, Assistant Director of Civil Works, in mid October. Comments from ASCE also were submitted Oct. 15, 2008.
Most notably, the commenters said, the P&G must focus on public health, safety and welfare. “The devastation caused by Hurricanes Katrina, Rita and Ike underscores the need for water resources planning to have a primary national objective to protect human life,” the WRC says. “The proposed Principles do not meet our nation’s critical need for a national public safety standard for flood risk management. The inclusion of addition considerations such as ‘alternative plans’ and the changes to the benefit-to-cost ratios demonstrates that public safety is not truly integrated, but merely a consideration.” Pallasch and Giamberadino also said that the state of our environment affects quality of life. “Consideration of environmental quality provides the basis for balancing both economic and ecological values in seeking to minimize and avoid impacts to the environment in formulating solutions to water resources challenges.”
ASCE’s comments prepared by Michael Charles, Senior Director Government Relations, state that the proposed revisions emphasize net economic benefit of industrial development over all other values. “The Corps should conduct analyses that attempt to assess the potentially detrimental impact of human activities on the ecosystem,” ASCE said. “To put it another way, the P&G should consider the likely positive economic benefits of not doing a project.”
Earlier this year, Pallasch testified that the current Principles need revision because they place benefit-cost analysis at the center of the planning process rather than addressing issues such as damage to the environment or the non-economic needs of society. Instead, Pallasch said, economic development should be considered on a life-cycle basis with a watershed approach, including water resources planning and regional sediment management. Such a plan would include core risk assessments, public participation and a collaborative process that determines how much risk is acceptable to communities when developing infrastructure for protection from natural hazards. In his testimony, Pallasch emphasized the need for a focus on public safety, economic development, environmental quality and other social effects.
Building on this testimony in its comments, ASCE said, a new strategy and approach for water resources planning and development is imperative, noting that, “we can no longer afford to focus on the narrow objective of national economic development.” Additionally, to avoid decision-making problems, ASCE said, the P&G should require the USACE to establish the economic value of environmental impacts and the risk to safety, health and welfare. Decisions on water resource planning need to recognize the positive economic impacts of projects within the national economic development objective, said Pallasch and Giamberadino. They note that flood damage reduction projects have prevented more than $700 billion in damage, provide $14.10 in return for every dollar invested, and in the Mississippi Valley and Tributary system save $24 in damage per dollar spent. Additionally, they said, development of our water resources fosters economic development, facilitates trade and commerce, enhances agricultural and industrial productivity and restores the environment, as well as producing a number of other benefits.
WRC said that projects should be planned and completed as needed. According to their comments, “alternatives may serve as a back door mechanism for reducing the scope of the projects.” They expressed concern that emphasis on alternate plans could become the norm. Their other concerns included: basing assessments only on limited factors that are clearly measurable; the use of objective peer review rather than a process that would back up USACE’s judgments; and the need to use the existing Principles until a new set are enacted into law.
“All peer review of civil works projects must be independent from the USACE to ensure that the public safety is adequately addressed, regardless of the BCR (benefit to cost ratio) or other economic considerations,” ASCE said. “Peer review should never be implemented to, however, merely to prevent or delay civil works projects that positively protect the public, health, safety and welfare.”
ASCE also notes that the analysis of non-structural project elements as “weak”. ASCE said the Corps should review this section to place greater emphasis on non-structural solutions to the engineering of water resources projects.
More than 100 comments received by the Assistant Director of Civil Works by Oct. 22 were posted to the USASCE website by late November. The second phase of the revision will include proposed changes to chapters two through four of the P&G. No dates have been set for release and comment on those documents.
The WRC is a multidisciplinary coalition that aims to ensure a comprehensive national water resource policy. For more information about the WRC or their comments, go to www.waterresourcescoalition.org. Brian Pallasch is the Managing Director of Government Relations for ASCE. Visit the ASCE Government Relations website at, http://content.asce.org/gr/.
