NPCA submitted the following position to the Senate Committee on Environment and Public Works ahead of a markup scheduled for May 2018.
The U.S. Army Corps of Engineers is an important partner in many places where NPCA works to protect and restore national park waterways and landscapes, the communities that surround them and the millions of people who visit them each year. From Gateway to the Grand Canyon, Everglades to Olympic, water is central to the features, wildlife, recreation and aesthetic of these esteemed places. However, national parks, once viewed as isolated and remote, are increasingly affected by activities occurring in their watersheds. These beyond park boundary activities often enhance or detract from the visitor experience.
Therefore, we are pleased to see the bill focus attention on restoring important ecosystems around our nation. From the Everglades (including the recently completed Kissimmee River Restoration Post Authorization Change Report and the upcoming one for the Central Everglades Project; Secs. 2307, 4001), the Great Lakes (including the Great Lakes Restoration Initiative and Great Lakes Fish and Wildlife Restoration Act; Secs. 3604, 3605, 3606) and the Hudson Raritan Estuary (expediting the completion of HRE restoration project; Sec. 2302), these areas are important to national parks and the introduced bill supports their restoration and protection.
We also appreciate the bill’s requirement that feasibility studies for flood risk management or hurricane and other storm damage projects must consider the use of both traditional and natural infrastructure alternatives (Sec. 1023). We have seen the benefits of incorporating and/or restoring natural infrastructure in Army Corps projects. Natural features not only often cost less, they also provide numerous benefits that come from integrating living breakwaters and other shoreline treatments, wetlands or other natural features into Army Corps projects. During Hurricane Irma in 2017, we saw firsthand how the nearly-completed Army Corps’ Kissimmee River Restoration project held significant amounts of water in the northern Everglades, as the historic floodplain once did, instead of channelizing large volumes of water quickly and directly into Lake Okeechobee, which could have caused catastrophic damage had the Herbert Hoover Dike breached. Natural features not only protect communities from storms; they also improve water quality and connect wildlife habitat, both of which are important for the health and enjoyment of park visitors.
Reforming the Army Corps’ benefit-cost procedures is important, and this bill takes a small step towards ensuring a full and accurate accounting of all the benefits and costs of Army Corps projects (Sec. 1003). We hope the bill’s Government Accountability Office study on benefit-cost analysis reforms looks at that the benefits of natural and nature-based features, which are often undercounted, miscounted or discounted. It will be important to see how the GAO describes current practice and how the BCR can be improved to reflect the known benefits of natural and nature-based options.
Additionally, while the drinking water, stormwater and wastewater infrastructure provisions do not fix the nearly $678 million in deferred maintenance needs for national park drinking water and wastewater systems, it does focus much needed attention and resources on the needs of those communities that national parks are in or near (Secs. 5004, 5005, 5006, 5010, 5011). We support the bill’s approach towards addressing our nation’s wastewater, drinking water and stormwater needs by advancing integrated water management approaches, increasing the availability of resources to more communities in need and promoting green infrastructure to address urban stormwater runoff.
Lastly, we deeply appreciate the committee rejecting roll backs of environmental laws and regulations that protect our national parks. Congress already enacted new Corps procedures designed to quicken project analysis and delivery in the last two WRDA bills. None of those changes have had adequate time to be fully implemented.
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Senior Director of Environmental Policy and Climate Change, Government Affairs