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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
Public Comments / April 15, 2024 / DownloadIn February 2024, the Army Corps of Engineers 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, our comments recommended several reasonable steps the Corps can take to make these ASPs even more effective.
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Comments to EPA and Army Corps of Engineers on Proposed Revised Definition of “Waters of the United States”
Public Comments / February 7, 2022 / DownloadThe Environmental Protection Agency and Army Corps of Engineers recently proposed a rule to return to the pre-2015 definition of the term “waters of the United States” under the Clean Water Act. We submitted comments encouraging the agencies to more fully elucidate the benefits from the proposed regulation, as the current economic analysis understates the rule's positive environmental effects.
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Comments to EPA and USACE on Clean Water Protections
The Environmental Protection Agency (EPA) and Army Corps of Engineers (USACE) have expressed the intention to repeal the Navigable Waters Protection Rule, which removed critical federal protections on many waterways and has been vacated by a federal court for violating the Clean Water Act. In comments filed to the agencies, we welcome the decision to replace the rule but encourage strong justification for reversing course and point to flaws in the economic analysis for the earlier rule that can support the case for replacing it.
We previously commented on the rule and its flawed economic justification, published a report on its concealed costs, and filed amicus briefs in court cases that challenged it.
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Comments to the Army Corps of Engineers on the Pebble Mine Project
Public Comments / July 1, 2019 / DownloadWe submitted joint comments on the Army Corps of Engineers’ environmental assessment of the Pebble Mine Project in southwest Alaska. The Corps quantifies greenhouse gas emissions from the project but fails to provide a monetized estimate of the climate damages those emissions will produce.
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Comments to Highway Administration and Army Corps on Addressing Greenhouse Gas Emissions
We submitted comments to the Federal Highway Administration (FHWA) and the US Army Corps of Engineers (USACE) on recent draft environmental impact statements (EISs), in which we stressed the importance of addressing climate impacts of proposed projects.
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Comments on U.S. Army Corps of Engineers Environmental Impact Statement
President Trump’s recent executive order on energy disbands the Interagency Working Group on the Social Cost of Carbon (IWG) and withdraws its technical support documents that underpin the IWG’s range of estimates. Instead, the executive order directs federal agencies to continue to monetize the social cost of carbon emissions pursuant to the Office of Management and Budget’s Circular A-4. In our comments, we highlight that the range of estimates from the IWG that agencies have been using, including the number used by the U.S. Army Corps of Engineers in the Draft Environmental Impact Statement, is consistent with Circular A-4 and therefore, consistent with the executive order.
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