71st SWCS International Annual Conference July 24-27, 2016 Louisville, KY

1. 2016 SWCS Annual International
Conference
Louisville KY
July 25, 2016
Noel Gollehon and George Townsley, NRCS
Rich Iovanna, FSA
Implementing the PR&G at USDA

2. Slide 2
United States Department of Agriculture
Natural Resources Conservation Service
Outline
• What is the PR&G?
• Why care about the PR&G?
• What was wrong with the P&G?
• How did we get here administratively?
• What are key features of the PR&G?
• Exclusions from the PR&G process.
• The why and what of USDA’s implementation
procedures.
• Status of USDA’s implementation procedures.
• Wrap-up.
Slide 2

3. Slide 3
United States Department of Agriculture
Natural Resources Conservation Service
What is the PR&G?
• Principles, Requirements & Guidelines for Federal
Investments in Water Resources
 Provides a common framework for analyzing Federal
investments in a range of water resources projects,
programs, activities, and related actions
 PR&G applies to a broad range of Federal investments
“that by purpose, either directly or indirectly, affect water
quality or water quantity, including ecosystem restoration
or land management activities”
 The framework applies to projects, programs, and
activities of Army Corps of Engineers, Departments of the
Interior, Commerce, Agriculture, along with TVA, EPA,
and FEMA
Slide 3

4. Slide 4
United States Department of Agriculture
Natural Resources Conservation Service
Why care about the PR&G?
• If seeking Federal funding for almost any water related
activity, the PR&G evaluation process may apply
 Army Corps dams, levees, locks, and restoration projects
 Bureau of Reclamation dams and irrigation infrastructure
 USDA-NRCS dams for flood control or other purposes
 USDA-RD programs for rural drinking water infrastructure
 EPA grant programs to improve water infrastructure
• The evaluation process may impact project’s funding
potential
• If a PR&G evaluation is required, there may be
significant administrative cost to conduct the analysis
Slide 4

5. Slide 5
United States Department of Agriculture
Natural Resources Conservation Service
What was wrong with the P&G?
• Principles, Requirements & Guidelines for Federal
Investments in Water Resources (PR&G) replaces
the P&G (Principles and Guidelines for Water and
Land Related Resources Implementation Studies):
 P&G were issued in 1983 (span of 33 years)
 P&G provided an evaluation framework for water and
related land resources implementation studies
 Applied to water resources project plans of the Corps of
Engineers, Bureau of Reclamation, TVA and Soil
Conservation Service (NRCS)
 The P&G required selection of the plan or project that
provided the greatest net economic development (NED
account), consistent with protecting the environment
(exceptions to NED plan were possible)
Slide 5

6. Slide 6
United States Department of Agriculture
Natural Resources Conservation Service
How did we get here
administratively?
• With great difficulty and very slowly!
• Congress instructed the Army Corps to revise the P&G as a
provision of the 2007 Water Resources Development Act
 The Corps revised the P&G in a manner unacceptable to the other
Agencies that use the P&G
• In 2009, the Council for Environmental Quality (CEQ)
assumed control of re-issue
 Reconcile differences in Agency’s language and approach
 Expanded the Agencies involved and the scope of the activities
evaluated
• In 2013, CEQ issued Principles and Requirements (the PR)
• In 2014, CEQ issued Interagency Guidelines (the G)
• Requires each Agency to issue detailed instructions
Slide 6

7. Slide 7
United States Department of Agriculture
Natural Resources Conservation Service
What are key features of the
PR&G?
• No single decision criteria
 Allows tradeoffs between economic, environmental and social
objectives to optimize across three goals
 Decision maker documents why decision was made.
• Federal objective (from 2007 WRDA)
 Maximize sustainable economic development
 Avoid unwise use of floodplains, and
 Protect and restore functions of natural systems and mitigate
unavoidable damage
• Principles beyond the Federal objective
 Public Safety
 Environmental Justice
 Watershed Approach
Slide 7

8. Slide 8
United States Department of Agriculture
Natural Resources Conservation Service
What are key features of the
PR&G?
• Core of the PR&G is a planning process to draw out the
benefits and costs of a potential water resources investment
in an ecosystem services context
 Relatively standard set of project evaluation steps, from defining the
issue to documenting the decision
 Described, quantified, and monetized benefits are considered
 Data adjustments allowed on smaller ($ & impact) projects
• Agencies have limited flexibility to:
 Specify requirements for the project evaluation steps
 Define the scale of “smaller” projects and projects below an evaluation
threshold
 Define included/excluded activities
Slide 8

9. Slide 9
United States Department of Agriculture
Natural Resources Conservation Service
Activities excluded from PR&G
 PR&G applies to a broad range of Federal investments
that by “purpose, either directly or indirectly, affect water
quality or water quantity, including ecosystem restoration
or land management activities”
 Several exclusions and exceptions to this broad statement
• Scale: Lower threshold of $10 million for projects, $50 million
annually for programs
• Activity: Regulatory activities, Research/monitoring, and emergency
actions
• Equivalent Pathway: An existing planning process is in place that
meets the purpose and intent of the PR&G for Federal investments
Slide 9

10. Slide 10
United States Department of Agriculture
Natural Resources Conservation Service
USDA’s implementation
procedures
• USDA has limited flexibility to:
 Specify standards for the accomplishment of the project
evaluation steps
• Basically following the requirements of NRCS watershed project
planning restructured to conform to an ecosystem services
perspective and to reflect the broader objectives
 Define the scale of “smaller” projects and projects below
an evaluation threshold
• Agencies may require a similar analysis for any project broader
objectives
Slide 10

11. Slide 11
United States Department of Agriculture
Natural Resources Conservation Service
USDA’s implementation
procedures
• USDA has limited flexibility to:
 Define included/excluded activities at the USDA agency
level
• Forest Service
– Included:
» Third-party water infrastructure development on Forest
Service Lands with a cost of more than $10 million (rare)
» Forest restoration with a water purpose costing more
than $10 million (rare event)
– Excluded: Land management planning activities and forest
related grants programs
Slide 11

12. Slide 12
United States Department of Agriculture
Natural Resources Conservation Service
USDA’s implementation
procedures
• USDA has limited flexibility to:
 Define included/excluded activities at the USDA agency
level
• Natural Resources Conservation Service
– Included: Activities conducted under Watershed Authorities
including rehabilitation (note that some RCPP projects rely
on these Authorities)
– Excluded: Farm Bill Conservation and Technical Assistance
Programs and activities under the Emergency Watershed
Program
Slide 12

13. Slide 13
United States Department of Agriculture
Natural Resources Conservation Service
USDA’s implementation
procedures
• USDA has limited flexibility to:
 Define included/excluded activities at the USDA agency
level
• Farm Service Agency
– Included: No programs at this time
– Excluded: Farm Bill Conservation and Support Programs
• Rural Development - Rural Utilities Service
– Included: Water and Waste Disposal Loan and Grant
Program (analysis conducted at a programmatic level)
– Excluded: Technical Assistance, Household water well
grants, and planning grants
Slide 13

14. Slide 14
United States Department of Agriculture
Natural Resources Conservation Service
USDA’s implementation status
• USDA will publish the procedures as a
Departmental Guidance that directs the Agencies to
conduct the analysis if needed
 Like other aspects of this effort, behind the deadline
 The Departmental Guidance will be finalized this fall
 NRCS will then revise its internal watershed planning
manuals and handbooks to reflect the revised guidance
 RD-RUS will develop procedures to incorporate the
PR&G in their water related loan programs at a
programmatic level
 FS and FSA will rarely, if ever, invoke the PR&G process
so it will be a revision to policy but likely no other action
Slide 14

15. Slide 15
United States Department of Agriculture
Natural Resources Conservation Service
Wrap-up
• The evaluation process for Federal investments in
water resources projects is being revised
• The revised process includes:
 More Agencies and activities
 Adopts an ecosystem services approach
 Increases project selection alternative options
 May be more rigorous for BIG projects (rare at USDA)
 May be less data intensive but more ecosystem service
driven for small projects (NRCS watershed programs)
 Impact of programmatic evaluations is unknown
(RD-RUS)
• CEQ guidance is final, USDA’s is underway

16. Slide 16
Noel Gollehon
Noel.Gollehon@wdc.usda.gov
301-504-1763
Thoughts and opinions presented today are those of the author and do not
represent those of USDA or the Natural Resources Conservation Service.