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Goals of presentation. Place the Administration's proposed Principles and Standards in a historical context and identify its inherent problems Look at the FY 2013 President’s Budget for affirmation of the policy signals articulated by CEQ’s draft Principles and Standards.

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goals of presentation
Goals of presentation
  • Place the Administration's proposed Principles and Standards in a historical context and identify its inherent problems
  • Look at the FY 2013 President’s Budget for affirmation of the policy signals articulated by CEQ’s draft Principles and Standards
what is the present federal planning model
What is the present Federal planning model?
  • The 1983 WRC Principles and Guidelines planning guidance is a simple constrained economic optimization model.
    • Monetized benefits and costs are given a pre-eminence over non-monetized benefits and costs.
    • Net “national” economic benefits (benefits minus costs) are to be maximized subject to environmental, legal and social constraints. (Each separable element of the project improves the economic merit of the total investment.)
    • Allows for addressing other concerns on an ad-hoc study-specific basis.
    • Selection of a plan other than the one that maximizes net benefits requires a rationale.
the p g s policy perspective
The P&G’s policy perspective
  • A Reagan Administration document that emphasized Civil Works projects as contributors to economic growth:
    • “The Federal Objective…is to contribute to national economic development consistent with protecting the Nation’s environment, pursuant to national environmental statutes, applicable executive orders, and other Federal planning requirements.”
  • Was to complement the cost-sharing reforms finally enacted in WRDA 1986
  • With the elimination of WRC funding, the lead in comprehensive planning and project integration was passed to the states and regions.
plan selection under the p g
Plan selection under the P&G

“A plan recommending Federal action is to be the alternative plan with the greatest net economic benefit consistent with protecting the Nation's environment (the NED plan), unless the Secretary of a department or head of an independent agency grants an exception to this rule. Exceptions may be made when there are overriding reasons for recommending another plan, based on other Federal, State, local and international concerns.”

policy issues emerged in subsequent administrations
Policy issues emerged in subsequent administrations
  • G. H. W. Bush Administration encouraged development of projects promoting fish and wildlife habitat. (Good for hunters and Fishermen!)
  • Clinton Administration made ecosystem restoration a Civil Works mission—gave an operational definition of “environmental enhancement.”
  • The Corps modified P&G plan formulation and plan selection guidance that was seen as unnecessarily restrictive.
corps responds
Corps responds
  • Planning Guidance Notebook (ER 100-2-100) in April 2000 made Ecosystem Restoration a Federal Objective.
    • Maintains requirements for incremental justification based on both monetary and non-monetary benefits of all separable elements including those for ecosystem restoration and for mitigation.
    • Long standing commitment to incremental analysis is affirmed despite SEC. 907 of WRDA 86. BENEFITS AND COSTS ATTRIBUTABLE TO ENVIRONMENTAL MEASURESwhich states:

“In the evaluation by the Secretary of benefits and costs of a water

resources project, the benefits attributable to measures included in a project for the purpose of environmental quality, including improvement of the environment and fish and wildlife enhancement, shall be deemed to be at least equal to the costs of such measures.”

plan selection in er 1105 2 100
Plan Selection in ER 1105-2-100
  • “Benefits can be monetary or non monetary, as in the case of ecosystem restoration projects. The process of optimizing net benefits should be reasonable and practical in seeking to maximize net benefits.”
why redo the 1983 principles and guidelines
Why redo the 1983 Principles and Guidelines?
  • The current guidance does not produce the project recommendations that many environmental interests want!
    • It may be that any project at all is recommended.
    • It may be that the recommended project does not comport with someone’s a priori expectations of a proper project.
    • It may be that the tradeoffs inherent in the project selection are not in accord with someone’s values and priorities, e.g.,inadequate mitigation.
what was to be the administration s solution
What was to be the Administration’s Solution?
  • Direct CEQ to redirect project planning outcomes
    • Develop new guidance-the Proposed Principles and Standards dated December 2009
    • Replace a simple constrained economic optimization with “Multiple Objective” planning
    • Make consideration of non-structural alternatives the first order of business in problem solving
    • Discourage use of floodplains for economic purposes
    • Abandon commitment to incremental justification for both separable elements and for mitigation measures
a new federal objective
A new Federal Objective
  • “The National Objective for water resources planning is to develop water resources projects based on sound science that maximize net national economic, environmental, and social benefits.”
  • “Consistent with this objective, the United States will demonstrate leadership by modernizing the way the Nation plans water resources projects by:
    • (1) protect and restore[sic] natural ecosystems and the environment while encouraging sustainable economic development;
    • (2) avoiding adverse impacts to natural ecosystems wherever possible and fully mitigating any unavoidable impacts; and
    • (3) avoiding the unwise use of flood plains, flood-prone areas and other ecologically valuable areas.”
why can t the new multiple objective paradigm succeed
Why can’t the new multiple objective paradigm succeed?
  • No way to tell Corps field planners how to credibly and consistently value non-economic concepts of “benefits” and “costs”—no broadly accepted theories of ecological value, and social value.
  • No way to tell field planners how to trade off among these values, however measured, in a way that will produce a recommendation that is sure to be endorsed by the Administration.
the current situation
The current situation
  • The proposed Principles and Guidelines are incoherent, and a National Research Council Committee said so.
    • Still struggling to make the guidance coherent.
  • Even if coherency is achieved, it can never be successfully implemented under the Corps’ decentralized planning approach.
  • Predications:
    • If any final guidance is ever released, it will be so vague as to be without operational meaning for field planners.
    • Signals will continue be sent though the authorization and budgeting processes that traditional projects are unwanted.
this year s budgetary signals
This year’s budgetary signals
    • Cano Martin Peña, PR
    • Chesapeake Bay Comprehensive Plan, MD, VA, PA, NY, WV, DE, & DC
    • Englebright and Daguerre Point Dams (Yuba River) Fish Passage, CA
    • Louisiana Coastal Comprehensive Study, LA & TX
    • Houston Ship Channel, TX
    • Water Resources Priorities Study
    • Lower Hamilton City, CA
    • Louisiana Coastal Area, Ecosystem Restoration, LA
    • Colorado River Basin, Onion Creek, TX
the message is clear
The message is clear
  • Ecosystem restoration and mitigation are increasingly important components of the Civil Works program.
  • The Administration’s values and priorities are reflected in its draft planning guidance but clear articulation is difficult; coherency requires resolution of formidable technical and policy conflicts.
  • The Budget contains clear signals.
  • There is no interest in a WRDA but that is not new.