Comments on Army Corps ASPs 2024.04.15-final

The Corps Should More Fully Integrate OMB Guidance into Its ASPs The proposal makes valuable progress on moving away from the historical and inefficiently narrow focus on national economic development to the exclusion of other essential objectives like environmental quality and distributional considerations.3 The proposal explains that the new “heart” of the ASPs is a broader evaluation of economi. [...] The Corps Should Include Tribal Effects in the Total Accounting of Net Public Benefits and Also in a Distributional Analysis Similarly, the Corps seeks comments on “whether the Corps should identify, characterize, and evaluate the benefits to the Tribal Nation separately, as opposed to including them in a broader assessment of the overall benefits.”29 But these are not mutually exclusive options. [...] The Water Resources Development Act of 2022 authorizes the Corps to now consider these different types of flooding in its analysis,38 and the proposal provides an opportunity for the Corps to add the necessary guidance on comprehensively weighing flood risk. [...] The proposal does endorse the use, where appropriate, of the social cost of greenhouse gases, though it somewhat strangely buries that in the preamble discussion of floodplains in Section 234.6 on the Planning Process.54 The Corps should instead clearly state in Section 234.7 (i.e., the section on how to evaluate benefits and costs) that commonly applied metrics like the VSL and the SC-GHG should. [...] Recommended Changes to Section 234.10: Compare Alternatives The Corps solicits comments on how to compare alternatives and evaluate tradeoffs,64 and in particular “whether the Corps should pursue a more straightforward approach, using maximizing the net benefits as a primary metric for use in comparing the alternatives and evaluating the tradeoffs, and to clarify the decision framework.”65 Through.