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Comments to the Army Corps of Engineers on Agency Specific Procedures to Implement the Principles, Requirements, and Guidelines for Water Resources Investments

In February 2024, the Army Corps of Engineers (the Corps) proposed a series of procedures to implement the governmentwide Principles, Requirements, and Guidelines for water-resource projects. The “heart” of these agency-specific procedures (ASPs) is ensuring that decisionmakers consider a wide suite of economic, environmental, and social benefits and costs as they invest in such projects. The proposal reasonably moves the Corps away from its historical and inefficiently narrow focus on national economic development to the exclusion of other essential objectives like environmental quality and distributional considerations.

While the proposal takes valuable steps toward more comprehensive accounting of societal benefits and improved decisionmaking, the Corps can take several reasonable steps to make these ASPs even more effective. Specifically, our letter explains that the Corps should:

  • Integrate OMB’s Circular A-94, Circular A-4, and ecosystem service guidelines more fully into its ASPs.
  • Revise the definition of “net public benefits” to explicitly include indirect effects, as well as private effects, and to capture total effects even as the incidence of effects (like to Tribes) may also be assessed in distributional analysis.
  • Clarify that more rigorous analysis may be warranted not just if a dollar threshold is exceeded but also if significant, non-monetized effects are likely to occur.
  • Offer more explicit guidance on considering a fuller range of flooding effects in the baseline, and more broadly cross-reference OMB’s guidance on forecasting baselines.
  • Update the final ASPs to reflect OMB’s final Ecosystem Service Guidance, and remove outdated references to older guidance documents.
  • Explicitly follow OMB guidance on risk, and encourage analysts to consider uncertainty about baseline conditions, like the functionality of local flood mitigation efforts.
  • Not set any upper limit for the temporal scope of analysis, and instead follow OMB guidance on both timeframes and discount rates.
  • Endorse use of the best available estimates of the value of statistical life as well as the social cost of greenhouse gases.
  • Eliminate the false distinction between the economic, environmental, and social categories.