principles, requirements, and guidelines for water and

Principles, Requirements, and Guidelines for Water and Land Related Resources Implementation Studies (PR&G)Use of PR&G in Water Resource PlanningMay 10, 2018

Support Documents• Section 2031 of PL 110-114 (WRDA 2007)• PR&G• DR 9500-013• P&G• Using Information on Ecosystem Goods and Services in

Corps Planning: An Examination on Authorities, Policies, Guidance, and Practices (USACE, 2013-R-07; September 2013)

• Caring for Our Natural Assets – An Ecosystem Services Perspective (USFS, October 2007)

• Towards Integrated Water Resources Management - A Conceptual Framework for U.S. Army Corps of Engineers Water and Related Land Resources Implementation Studies (2012-VSP-01, USACE-IWR, September 2012)

2NRCS Economics Website

https://www.congress.gov/110/plaws/publ114/PLAW-110publ114.pdf

https://obamawhitehouse.archives.gov/sites/default/files/final_principles_and_requirements_march_2013.pdf

https://obamawhitehouse.archives.gov/sites/default/files/docs/prg_interagency_guidelines_12_2014.pdf

https://www.ocio.usda.gov/sites/default/files/docs/2012/DM9500-013_final.pdf

https://www.nrcs.usda.gov/wps/portal/nrcs/main/national/technical/econ/

http://www.iwr.usace.army.mil/Portals/70/docs/iwrreports/EGS_Policy_Review_2013-R-07.pdf

https://www.nrs.fs.fed.us/pubs/31719

http://www.iwr.usace.army.mil/Portals/70/docs/iwrreports/2012-VSP-01.pdf

https://www.nrcs.usda.gov/wps/portal/nrcs/main/national/technical/econ/

To be covered• What is in PR&G• Comparison of PR&G to P&G• Impacts of PR&G on Planning

and Analysis• Impacts to Economic Analysis• Ecosystem Services• Display Changes

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Authority for PR&G• Water Resources Planning Act of 1965 (PL 89-80)• Law Created the Water Resources Council • Law Instructed the Council to Prepare Consistent

Evaluation Procedures for Water Resources Project Investment for the President

• Congress requested the Update in Section 2031 of the Water Resources Development Act of 2007 (PL 110-114)

• The Principles, Requirements, and Guidelines (2014) is the fourth version of these instructions

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Federal Objective (Sec 2031a of PL 110-114)(1) seeking to maximize sustainable economic development;(2) seeking to avoid the unwise use of floodplains and flood-prone areas and minimizing adverse impacts and vulnerabilities in any case in which a floodplain or flood-prone area must be used; and(3) protecting and restoring the functions of natural systems and mitigating any unavoidable damage to natural systems.

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Sec 2031b(3) of PL 110-114 Guidance for PR&G

(A) The use of best available economic principles and analytical techniques, including techniques in risk and uncertainty analysis.(B) The assessment and incorporation of public safety in the formulation of alternatives and recommended plans.(C) Assessment methods that reflect the value of projects for low-income communities and projects that use nonstructural approaches to water resources development and management.(D) The assessment and evaluation of the interaction of a project with other water resources projects and programs within a region or watershed.(E) The use of contemporary water resources paradigms, including integrated water resources management and adaptive management.(F) Evaluation methods that ensure that water resources projects are justified by public benefits.

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PR&G Contents• Chapter 1 - Principles

• Chapter 2 - Requirements

• Chapter 3 - Interagency Guidelines

• Chapter 4 – Agency Specific Procedures

• Department Regulation and

• Manual (DM 9500-013)

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Chapter 1 - Principles• Federal Objective (PR&G 1.2)

– (1) maximize sustainable economic development;– (2) avoid the unwise use of floodplains and flood-prone areas– (3) protecting and restoring the functions of natural systems and

mitigating any unavoidable damage to natural systems.• Not applicable to Regulatory, Research, or Monitoring• Applies to more than PL 83-566 Efforts by definition:

Federal investments that by purpose, either directly or indirectly, affect water quality or water quantity, including ecosystem restoration or land management activities

• Maximize public benefits relative to cost• No Hierarchal relationship among goals

– (1) Economic– (2) Environmental– (3) Social

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Chapter 1.3 – Guiding PrinciplesGuiding Principles New Existing Requirements

Healthy and Resilient Ecosystems

No Mitigation under NEPA, EO11988 (FP), EO11990(WTL), EO13089 (Coral) , EO13112 (Invasive), etc.

Sustainable Economic Development

No Mitigation under NEPA, 404b1 Permitting, EO12898 (EJ), other EOs

Floodplains No EO11988 (May 24, 1977); 7CFR650.25

Public Safety No EO11988 and NWPM

Environmental Justice No EO12898 (February 11, 1994)

Watershed Approach No NPPH and NWPM

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Chapter 2 - RequirementsRequirements New Existing or Previous GuidanceEvaluation Framework (Ecosystem Services)

Yes Framework is similar to previous PL 89-80 related guidance, and NPPH with a Big Accounting Twist

Best Available Science and Commensurate Level of Detail

No Similar to NEPA requirements to match analysis to significance of impacts and P&G allowing abbreviated procedures.Removed requirement to go to Water Resource Council for new procedures

Collaboration No NEPA requires invitation of “Cooperating Agencies”

Risk and Uncertainty Yes Partial change as PR&G specifies some items for disclosure

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Chapter 2 – Requirements (cont.)Requirements New Existing or Previous GuidanceRisk and Uncertainty- Climate change Yes Requirement only in PR&G since

EO13653 was removed (March 2017) by EO13783

- Future land use No Required in forecasting for planning- Adaptive management No Used more explicitly in conservation

practices and design for remedial workWater Use No Climate change Presidential Memo and

need for setting criteria for water demand analysis

Nonstructural Approaches

No Required by EO11988, EO11990, NWPM, etc.

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Chapter 2 – Requirements (cont.)Requirements New Existing or Previous GuidanceInternational Concerns No Part of P&G (1.4.2)Design of Alternatives Yes Alt Identification – Locally Preferred

Existing identification - Env Preferred (ROD); Non-structural; may add Economic and Social

Transparency of Decision Making

Yes Partial change due to requiring full trade-off analysis via display and discussion

Plan Selection YES Full disclosure of all trade-offs among final array of alternatives.No hierarchal selection criteria among goals (Economic, Environment, and Social)

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Chapter 3 - Interagency GuidelinesRequirements New Existing or Previous GuidanceProject and Programmatic analysis

Yes Previously water resource projects only

Analysis intensity based on $$

Yes Previously no threshold

Integrate into NEPA Processes

No Same

Collaboration on Planning

No Part of previous guidance

Developing Conceptual Models

Yes NRCS has network diagrams but they do not label Ecosystem Service flows

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Chapter 3 - Interagency GuidelinesRequirements New Existing or Previous GuidanceEcosystem Service Accounting

YES New Accounting system

Display with Tradeoffs Yes Similar to Summary and Comparison Table but Ecosystem Services added

8-step Planning process

No 9-steps that cover required 8-steps

Agency Prepares ASP Yes Previous guidance had Chapter 2 and 3 for Procedures

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Chapter 4- Interagency Guidelines

• Analytical Requirements• Peer Review • Integration with NEPA

• Applicability to NRCS Programs

• Economics• Ecosystem Services

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NEPA and PR&G

NEPAPurpose and Need

Reasonable Alternatives

PR&G Federal Objective Guiding Principles (may not be in P&N)

Nonstructural AlternativeLocally Preferred Alternative

Disclosure of Alternative tradeoffs for Ecosystem Service Flows comparing to Federal Objective and Guiding Principles

16DM 9500-013 pages 5 to7

Applicability of PR&G to NRCS ProgramsExempt or Equivalent Pathway (EP)• EWP Exigent work – Exempt• EWP Non-exigent work - EP• Farm Bill Programs - EP

Applicable• PL 83-566 • PL 78-534, Section 13• Use of PL 83-566 Authority

– RCPP – Other Program decisions

Source: Section 5 and Table 5 of DM 9500-013 Guidance for Conducting Analyses Under the Principles, Requirements, and Guidelines for Water and Land Related Resources Implementation Studies and Federal Water Resource Investments

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Applicability of PR&G to NRCS ProgramsExempt or Equivalent Pathway (EP)• EWP Exigent work – Exempt• EWP Non-exigent work - EP• Farm Bill Programs - EP

Applicable• PL 83-566 • PL 78-534, Section 13• Use of PL 83-566 Authority

– RCPP – Other Program decisions

Source: Table 5 of DM 9500-013 Guidance for Conducting Analyses Under the Principles, Requirements, and Guidelines for Water and Land Related Resources Implementation Studies and Federal Water Resource Investments

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Chief signed Decision Memo on April 4, 2018

What Stuck from the PR&G Big Changes

• Applicability from a federal investment that affects water quantity and quality– Equivalent Pathway– PL 83-566 and PL 78-534 Authority

• Full Documentation of all Decisions – No NED anymore– Non-Monetary Benefit and Cost Emphasis – Increased Decision Flexibility– Increases Program Oversight for decision consistency

• Ecosystem Services Accounting of Benefits and Costs• Procedures are not prescriptive as previous guidance

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Economics

P&G• OMB Circular A-94 was not

applicable• Update methods with

approval by WRC and brought by Secretary (2.1.1b(3))

• Chapter 2 - Descriptive “How To” guide

PR&G• OMB Circular A-4 and A-94

are now applicable• Update methods with

approval from USDA Chief Economist (Section 9, page 36)

• DM 9500-013 not built as a “How To” guide

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Common Assumptions - Same

• Full Employment• Period of Analysis• Prices• Technology• Discount Rates

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Economics for PL 83-566

PR&G Categories

• Benefit-Cost Analysis• Cost-Effectiveness

Analysis• Breakeven Analysis• Incremental Analysis• Regional Impact

Analysis

Source: DM 9500-013 Guidance for Conducting Analyses Under the Principles, Requirements, and Guidelines for Water and Land Related Resources Implementation Studies and Federal Water Resource Investments

Incremental AnalysisCost AllocationSeparable Costs

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PR&G - Benefits

Use Values – Direct and Indirect use• Actual or simulate market

price• Change in Net Income• Cost of Most Likely

Alternative• Avoidance Expenditure• Hedonic Evaluation• Agent Based Modeling• Contingent Valuation• Conjoint Analysis • Travel Cost

Non-Use Values – Existence and Bequest

• Contingent Valuation• Conjoint Analysis• Proxy Values

– Administrative Values– Benefit Transfer

• Other Direct benefits and Externalities


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P&G Methods Still Applicable

P&G Chapter 2

• M&I Water (P&G 2.2)• Ag Flood and Irrigation (P&G

2.3)• Urban Flood (P&G 2.4)• Recreation (P&G 2.8)• Commercial Fishing (P&G 2.9)• Other Direct Benefits (P&G 2.10)• Un/Under Employment (P&G

2.11)• Cost Procedures (P&G 2.12)


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Costs - Same

• Implementation Outlays• Associated Costs• Other Direct Costs and

Externalities (Induced Damage)

Still an average annual analysis over a comparable Period of Analysis

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Economic and Trade Off Tables• Economic Tables still based on Preferred Alt• National Economic Development is now National Economic

Efficiency• Increments will be displayed as necessary in tables

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Final Array of Alternatives for Evaluation

P&G• No Action/Future Without

Project• FWP - NED• FWP - All other reasonable

alternatives

PR&G • No Action/FWOFI• FWFI

• Non Structural Alternatives• Locally Preferred Alternative• Environmentally Preferred

Alternative (from NEPA)• All other reasonable

alternatives

Optional FWFINational Economic EfficiencySocially Preferred

*Conflict between PR&G and DM on Non StructuralFWOFI = Future Without Federal investmentFWFI = Future With Federal Investment27

Evaluating Alternatives under PR&GEvaluation Categories• Public benefits of

alternative are compared to costs

• Performance against guiding principles

• Performance against formulation criteria

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Source: Chapter 3, Page 21

Ecosystem Service Accounting

• Required in Presidential Memorandum M-16-01

• Based on Millennium Ecosystem Assessment

• Ecosystem Services

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Ecosystem Service Framework• Categories are based on 2005 Millennium Assessment• Selection of Ecosystem Services and Metrics

• Scoping of relevant concerns• Selection of services• Identification of appropriate metric

• Changes of Services• Impact (direct, indirect, and cumulative)• Reversibility of decision• Irretrievability of potential resource foregone• Local societal importance of resource• Potential to affect pre-existing regulatory threshold

• Characterization of relative change• Consideration and prioritization of ecosystem services and values• Distributional differences• Characterization of values and tradeoffs

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Ecosystem ServicesService Example Evaluation

Provisioning Food, fiber, freshwater, timber, genetic resources, etc.

Mostly market values

Regulating Regulation of air, climate, disease, erosion, natural hazards and pestPollination and water purification

Market values/WTP

Cultural AestheticsRecreation and EcotourismSpiritual and religious values

Non Use Values – Option or Existence value

Supporting Nutrient cycling, soil formation, and primary production

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Ecosystem Services ExamplesScoping Provisioning Regulating Cultural

Air quality Disease Control

Coral reefs Food web Storm Protection

Cultural resources Social Value

Ecologically critical areas Genetic Resources option Values

Endangered and threatened species

Genetic Resources Existence Values

Environmental justice and civil rights

Social Justice

Essential fish habitat Fish Productivity RecreationFish and wildlife (including coordination requirements)

Productivity Recreation

Floodplain management Storm Protection

Forest resources Timber Water Regulation Recreation

Invasive species Food, fiber, etc Aesthetics

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Ecosystem Services Examples (Continued)Scoping Provisioning Regulating Cultural

Land use Crop/Urban Runoff Change Viewshed

Migratory birds Food Recreation

Natural areas Aesthetics

Parklands RecreationPrime and unique farmland, and farmland of statewide significance

Food, fibers, etc.

Public health and safety Flood control

Regional water resource plans (including coastal zone plans)

Water Regulation

Riparian areas Clean Water Flood control

Scenic beauty Aesthetics

Scientific resources Archaeological

Sole source aquifers Clean Water

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Ecosystem Services Examples (Continued)Scoping of Resource Concerns Provisioning Regulating Cultural

Social issues Social

Soil resources Food, fiber, etc.

Water qualityClean Water Disease

controlAesthetics

Water resources Water useWaters of the United States, including special aquatic sites

Water filtration

Wetlands Timber Flood control Aesthetics

Wild and scenic rivers Recreation

Other concerns identified

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Preferred AlternativeP&G

– NED Plan– Exception with supporting

rationale

PR&G – No hierarchal requirement among

goals (econ, social, env)– Develop Tradeoffs – Document Rationale for preferred

related to tradeoffs – Support of Guiding Principles

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Selection Criteria• Complete discussion of

trade-offs• How Economic,

Environmental, and Social benefits justify cost

• Disclose tradeoffs between goals and Guiding Principles

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No Exceptions and NWPM 502.2 goes away

Chapter 1 – Principles (Recall)

• Federal Objective (PR&G 1.2)– (1) maximize sustainable economic development;– (2) avoid the unwise use of floodplains and flood-prone areas– (3) protecting and restoring the functions of natural systems and

mitigating any unavoidable damage to natural systems.• Not applicable to Regulatory, Research, or Monitoring• Applies to more than PL 83-566 Efforts by definition:

Federal investments that by purpose, either directly or indirectly, affect water quality or water quantity, including ecosystem restoration or land management activities

• Maximize public benefits relative to cost• No Hierarchal relationship among goals

– (1) Economic– (2) Environmental– (3) Social

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Chapter 1.3 – Guiding Principles (Recall)Guiding Principles New Existing Requirements

Healthy and Resilient Ecosystems

No Mitigation under NEPA, EO11988 (FP), EO11990(WTL), EO13089 (Coral) , EO13112 (Invasive), etc.


No Mitigation under NEPA, 404b1 Permitting, EO12898 (EJ), other EOs

Floodplains No EO11988 (May 24, 1977); 7CFR650.25

Public Safety No EO11988 and NWPM

Environmental Justice No EO12898 (February 11, 1994)

Watershed Approach No NPPH and NWPM

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Guiding Principle – Healthy and Resilient Ecosystems “Federal investments in water resources should protect and restore the functions of ecosystems and mitigate any unavoidable damage to these natural systems”• Does the alternative works protect and restore ecosystem

functions and values?• Does the alternative create an irrevocable impact on the natural

system?• What is the recovery time for the ecosystem based on impacts

of implementation?• Does the alternative provide for compensatory mitigation to

unavoidable damages to natural systems?

Place check in table that best supports this PR&G principle.

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Guiding Principle – Sustainable Economic Development “Alternative solutions for resolving water resources problems should improve the economic well-being of the Nation for present and future generations through the sustainable use and management of water resources ensuring both water supply and water quality. Sustainable in this context means the creation and maintenance of conditions under which humans and nature can coexist in the present and into future”• Economic – personal income and distribution, job growth, etc.• Social – poverty stats, unemployment, public safety, etc. • Environmental – Pollutants, land use/land cover change, etc.


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Guiding Principle – Floodplains“Floodplains that have not been adversely affected can sustain their natural functions and increase the resilience of communities. For this reason, Federal investments in water resources should avoid the unwise use of floodplains and flood-prone areas and minimize adverse impacts and vulnerabilities in any case in which a floodplain or flood-prone area must be used.”• Is action consistent with 11988 and 7CFR650.25?• Is there an increase in flood risk from the baseline condition?• Is there a flood risk transfer (geographically, socio-economically,

generationally, etc.)?


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Guiding Principle – Public Safety “Alternative solutions, which include structural and nonstructural elements, must avoid, reduce, and mitigate risks to the extent practicable and include measures to manage and communicate residual risks.”• Does the floodplain still have a population or critical

infrastructure at risk of breach?• Does the upstream still have a population or critical

infrastructure below to PMP elevation?


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Guiding Principle – Environmental Justice “Environmental justice is the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. Agencies should ensure that Federal actions identify any disproportionately high and adverse public safety, human health, or environmental burdens of projects on minority, Tribal, and low-income populations.”• Transparency and engagement of minority, low income, other

disadvantaged communities (EJ Groups)• Evaluation of alternative outcomes for affected EJ Groups

(disparate impacts)• Impacts on EJ group health, income, subsistence living, cultural

resources, etc. Place check in table that best supports this PR&G principle.

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Guiding Principle – Watershed Approach “A watershed approach to analysis and decision making facilitates evaluation of a more complete range of potential solutions and is more likely to identify the best means to achieve multiple goals over the entire watershed. A watershed approach facilitates the proper framing of a problem by evaluating it on a system level to identify root cause(s) and its interconnectedness to problem symptoms.”• Does the alternative effect resources outside the watershed?• Alternative effects on current and future habitat impacts?• Alternative effect to conserve sensitive species or habitats or

other natural resources?• Cumulative impact of alternative relative to past water

development and other planned developments?• Does alternative address chronic environmental problem?Place check in table that best supports this PR&G principle.

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Summary and Comparison Change• Similar structure to existing table• The DR sample uses Ecosystem

Services where P&G had the four accounts

• Check off of meeting PR&G Principles

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Layout: Summary and Comparison TableAlternatives No Action (FWOFI) Alt 1 (FWFI)MAJOR COMPONENTS/FEATURES .

Optimizing CriteriaNon-StructuralLocally PreferredEnvironmentally PreferredNational Economic EfficiencySocially Preferred

Guiding PrinciplesHealthy and Resilient EcosystemsSustainable Economic DevelopmentFloodplainsPublic Safety

Environmental Justice

Watershed Approach

Ecosystem Services

Provisioning

Regulating

Cultural46

√

√

Summary Env. ConsequencesMonetary

Non-Monetary

Example Summary and Comparison WSOPS • Need

• Clear Creek is flooding of four roads, fifteen houses, and a school in Near Lake Watershed

• Sponsor wants to provide some recreation opportunities

• No Action or Future Without Federal Investment (FWOFI)

• Sponsor will install a levee to protect to the 50-year or 2% flood recurrence

• Future With Federal Investment (FWFI) – Alt B• Install a single purpose high hazard structure that will protect to

100-year or 1% flood• Install a levee for school to protect to 500-year or 0.2% flood

recurrence• Community to participate in National Flood Insurance Program

and adopts zoning to stop new development within 1% annual-chance floodplain and adopts land-use planning to keep critical structures out of 0.2% flood elevation.47

Example Summary and Comparison WSOPS (Continued)• Future With Federal Investment (FWFI) – Alt C

• Alt B• Sponsor installed recreation development

• Future With Federal Investment (FWFI) – Alt D• Relocate 6 houses and floodproof 9 houses• Raise four roads• Install a flood wall to protect a school to 0.2% annual-chance

flood (500-year recurrence)• Community to participate in National Flood Insurance Program

and adopts zoning to stop new development within 1% annual-chance floodplain and adopts land-use planning to keep critical structures out of 0.2% flood elevation.

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Example Summary and Comparison WSOPS (continued) - Supporting Notes• State Comprehensive Outdoor Recreation Report

• No large demand for additional small lake recreation in the region• Multiple lake recreation sites occur in the region

• Alternatives Eliminated from Detailed Study• Multipurpose dam – Multiple alternative recreation sites within 20 mile

radius of propose dam location• 500-year flood protection – The extra protection did not provide net

benefits, added cost was not reasonable from a NEPA perspective, and works do not support PR&G Federal objectives or guiding principles.

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Summary and Comparison Table

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Alternative No Action/FWOFI

Alt B (FWFI) Alt C (FWFI) Alt D (FWFI)

Major FeaturesLevee to 2% Flood

High Hazard dam 1% Flood, levee for school 0.2%

Alt B + Recreation (sponsor only)

Relo/FPFlood wall for school

Alternative PlansNon-Structural √

Locally Preferred √

Environmentally Preferred

√

National Economic Efficiency

√

Socially Preferred √


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Guiding PrinciplesHealthy and Resilient Ecosystems

√


√

Floodplains √Public Safety √Environmental Justice √Watershed Approach √


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Project Investment (financial outlay)

$1.3MM $1.46MM $1.86MM $3.5MM

Federal PL 83-566 $730K $730K $1.75MMFederal Other/aLocal only or Matching PL 83-566

$1.3MM $730K $1.13MM $1.75MM

Local Matching Other Federal

Average Annualized Cost and O&M

$55,400 $56,800 $72,600 $136,100

Federal PL 83-566 $48,200 $54,100 $69,100 $129,600Federal Other/a

Annual O&M PL 83-566 $7,200 $2,700 $3,500 $6,500Annual O&M Other Fed

Summary and Comparison Table1

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Trade-Offs

Provisioning

Wetlands5 acres woodland habitat lost

5 acre woodland habitat lost

Wetland Mitigation Cost $15,000 $15,000

1 All monetary cost and benefits are in average annual values over evaluated life.


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Trade-Offs

Regulating

Flood prevention

2% Flood 1% Flood, 0.2% Critical

Structure

1% Flood, 0.2% Critical

Structure

1% Flood, 0.2% Critical

Structure

Flood remaining damage $40,000 $5,000 $5,000 $5,000Flood prevention Cost $27,700 $36,900 $36,900 $85,000

Floodplain acres Reduce by 2 acres

Reduce by 5 acres

Reduce by 5 acres



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Alt B (FWFI)

Alt C (FWFI) Alt D (FWFI)

Trade-Offs

Cultural

Recreation User Days1,800 user days. Substitution with other regional sites

Recreation Cost $15,000Recreation Benefits $14,900


Summary• Similar to 1983 P&G with all of the other Laws and

Executive Orders applied• Applicable beginning June 1st (per Chief Decision Memo) to

all water resource projects using PL 83-566 or PL 78-534 authority regardless of federal investment

• Economics relatively unchanged• Changes

– Ecosystem Services Framework required– No hierarchal decision criteria– Required alternative plans in final array– Full disclosure of tradeoffs (quantification where possible)

• Summary and Comparison changed for Ecosystem Services

– Key showing monetary and non-monetary trade-offs in this table– Documenting monetary and non-monetary trade-offs in Environmental

Consequences– Documenting rationale for preferred alternative addressing trade-offs of

alternatives and support for PR&G Objectives & Guidelines from Chapter 156

Questions

E-mail questions and comments to Kevin Farmer, Jesse Wilson, and George Townsley on this recommended process for meeting PR&G in our plans that use PL 83-566 and PL 78-534 authority.

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mailto:[email protected]

