Originally published here by UGA’s Institute for Resilient Infrastructure Systems. Article by Yee Huang, UGA.
IRIS affiliates are contributing their expertise as the US Army Corps of Engineers updates its policies for evaluating potential new civil works projects. The Corps recently proposed new Agency Specific Procedures (ASPs) to implement the Principles, Requirements, and Guidelines (PR&G). IRIS Director Brian Bledsoe, along with law and policy experts Yee Huang and Matthew Shudtz, recently filed comments on the proposal, supporting the key policy changes and encouraging various technical amendments that would further enhance implementation of resilient infrastructure systems.
Since the New Deal era, the Corps has been evaluating water resources projects and alternatives by comparing benefits to costs. The 1983 Economic and Environmental Principles and Guidelines for Water and Related Land Resources Implementation Studies (P&G) laid out a single objective – to contribute to national economic development, defined as the net value in monetary terms of the national output of goods and services.
Twenty-five years later, the 2007 Water Resources Development Act (WRDA) directed the Secretary of the Army to revise the 1983 P&G with a new policy that emphasized the environmental and social benefits of water resources projects. That new policy eventually was documented in the 2012/2013 PR&G, which set government-wide policies for water resource investments that emphasized multiple objectives: environmental justice, wise use of floodplains, healthy and resilient ecosystems, public safety, sustainable economic development, and a watershed approach to planning. Since then, several other federal agencies have developed their own agency-specific procedures for implementing the PR&G. The 2020 WRDA also called for the Army to develop and issue ASPs, leading to the current proposed rule.
IRIS affiliates engaged in conversations (including a recent webinar) about how the Corps’ ASPs might contribute to more resilient infrastructure systems. Brian Bledsoe, Todd Bridges, Susana Ferreira, Katie Foster, Yee Huang, Craig Landry, Alec Nelson, Matthew Shudtz and Charles van Rees each drew from their work in the field and contributed to advancing policies for evaluating Corps civil works projects.
Our comments welcome and applaud the Corps’ proposed rule, which marks a significant evolution of how the agency will evaluate alternative solutions to flood and coastal storm risk management, environmental restoration projects, and more. It flattens the former hierarchy among economic, environmental, and social goals by mandating net public benefits be maximized. This new federal objective establishes equivalency in monetized, quantified terms and un-monetized, unquantified terms among these three goals and leaves behind the sole focus on economic development.
The proposed rule also requires a final array of six alternatives to address a water resources development problem, and both a nature-based alternative and a non-structural alternative must be among the final array. Moreover, all alternatives must consider nonstructural or nature-based solutions, a strong signal of support for these options. Our comments focus on amendments and additions that ensure that these green solutions will be thoroughly considered during the project selection process and that increase the likelihood that they will be ultimately implemented in practice.
Additionally, N-EWN partners at Duke University’s Nicholas Institute for Energy, Environment, and Sustainability hosted a webinar on the rule making on April 2. Look for the recording of the webinar at this site.
The full comments are here.
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