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Fighting coastal red tape – part two


red tape on coast

Editor’s note: This is the second in a two-part piece on a press release from Governor Jindal’s office that specified problems and proposed solutions to the incredibly slow progress on coastal protection and restoration.

Part one involved concerns (impediments to progress) and part two (here) focuses on solutions. The following text includes ten specific recommendations from the governor’s office (indented and italicized) followed by my comments. Additional comments from outside unnamed authorities are shown in indented italicized paragraphs at the bottom.

I’m glad to see the governor’s office put specific red tape-cutting recommendations on the table. No one who cares about south Louisiana is happy with the current pace of dealing with the crises. The objective of this post is to encourage scrutiny and discussion of these recommendations so as to help achieve real streamlining and avoid unintended consequences.  


Publishing this post on July 28 is timed to coincide with three evening meetings (July 28, 29 and 30) in Lake Charles, Houma and Harahan, respectively, to encourage public input on streamlining the corps of engineers. These meetings are being hosted by Gov. Jindal’s office. See upcoming events for details.

Suggested Interim Actions to Quickly Address Proposed Concerns

1) Elevate New Orleans Corps District Office to Division Office:

Re-establishing the New Orleans Corps District to a Division commanded by a General would increase efficiency, reduce timing of decisions and improve the accuracy of communication mong the various Corps’ layers.

The word “re-establishing” implies that New Orleans once had division status, which is news to me. This recommendation is provocative and worthy of serious discussion. I would propose expanding the Mississippi River Division, no matter where it is headquartered, to include the Mobile District and perhaps Galveston, as well as the upriver districts. I witnessed very poor communication between the New Orleans and Mobile districts after Katrina. Attracting first rate division commanders and their top staff to the Big Easy, as opposed to sleepy Vicksburg, should be a piece of cake!

2) Extend Tour of Command at New Orleans Corps’ Office:

The Corps of Engineers currently cycles their commanding officers on two to three year tours through New Orleans. The issues facing coastal Louisiana are so unique and complex, it takes at least this long to merely understand these challenges much less address them. The Corps should extend the tour of the New Orleans office commander to a term of five years.

I support this recommendation, with one caveat: the best district commanders tend to leave the Army after being assigned to New Orleans because they’re the ones who make waves and are not promoted. Col. Mike Diffley was the first district commander to take on coastal restoration and he was the brightest, most critical and potentially most effective DC I ever met. He once spent time on a Sunday afternoon talking policy with me and the DNR assistant secretary on Ivor van Heerden’s sailboat! Diffley was a serious commander and generally unpopular with his staff. I remember the glee on Leake Avenue at the end of Mike’s tenure in 1994, when he went off to teach math in a poor school in NY City.  

I won’t name the worst DC I have known, who candidly acknowledged avoiding controversy on his watch so as to remain on track for promotion to Brigadier General. Tenure in New Orleans should only be offered to outstanding leaders. 

3) Establish Guidance for Working on a Deltaic Plain:

Conditions within a deltaic plain are very dynamic. The environment often shifts during the planning, designing or implementation of a project. Swift actions and adaptive management are essential to successfully implementing work. The establishment of guidelines for functioning within a Deltaic Plain would allow the Corps of Engineers to make necessary adjustments without redesigning the entire project and generating unnecessary delays.

This recommendation is unclear. I agree that saving the largest delta in North America is more challenging than dealing with any other coast on the continent but many state and parish officials have little room to criticize the corps for not recognizing that “deltas are different.” A large proportion of stakeholders in south Louisiana also seem oblivious to our deltaic status – especially the “levees-only” advocates who seem to be getting louder.

4) Establish Alternative Arrangements for NEPA:

The White House Council on Environmental Quality is empowered to grant alternative arrangements for compliance with the National Environmental Policy Act (NEPA). Protection and restoration activities that are designed to re-establish or protect coastal wetland ecosystems, or benefit the environment, should not be forced through a multi-year process to determine the environmental impact of such project. Similarly, alternatives should be established that are representative of the urgency of hurricane/flood protection and coastal restoration needs in our state.

This recommendation reminds me that during 1996 there was a panic about new NOAA rules about essential fish habitat (EFH), which some feared would make restoration projects “unlawful.” It didn’t happen. On the other hand I agree that national standards need flexibility for local conditions (see comments on our unique deltaic status). For example, I share concerns that the development of national Total Maximum Daily Loading (TMDL) standards could preclude river diversions on the basis of high concentrations of nitrate in Mississippi River water. 

5) Require Transition Plans for FEMA and Corps Policies:

FEMA and the Corps should evaluate the cumulative impact of these policies and coordinate efforts to improve the resiliency of coastal communities while allowing for the flexibility needed to comply with updated standards. In a similar case in California, the region was allowed ten years to comply with updated standards. No such transition was allowed in Louisiana.

I have serious concerns about the state requesting time to adjust to new standards. For example, piling up dirt as a quasi-levee without sufficient geotechnical information may increase risk. I also see no public value in delaying requirements for home elevation in areas at high risk for storm surge. Serious coastal protection will require politically unpopular decisions.

6) Liberally Exercise Section 211 of WRDA 1996 in Louisiana:

Section 211 allows for States, levee districts and parishes to carry out restoration and protection projects without Corps of Engineers’ participation. The Corps reimburses these non-federal entities for 65% or greater of the project cost. State and local entities have the capability to quickly execute critical hurricane/flood protection and coastal restoration project – their efforts should not be constrained, delayed and cost inflated by Corps’ policies and bureaucracies.

I’m not sure that I understand this recommendation, which suggests that the lay public will also be confused. Less jargon, please!

7) Require Beneficial Use of Dredge Material:

Legislation establishing a progressive timeline mandating the beneficial use of the material should be created. Requiring beneficial use of dredged material is a necessity for the long-term resilience of Coastal Louisiana. Sediment is a critical resource to our state that should be fully-utilized.

I strongly support the maximal beneficial use of material dredged from channels but requiring ALL material dredged from channels to be used beneficially would be extremely expensive in dollars and energy and therefore unrealistic. See part one of this series.

8) Direct Mitigation Funds to Large-Scale Efforts:

Mitigation funds should be combined and directed toward the implementation of the large-scale restoration efforts. Congress has authorized $6-8 billion in coastal restoration projects in our state, but funds have not yet been allocated. The use of these mitigation funds could solve two problems quickly.

I concur.

9) Restore and Maintain Navigation Channel Banks:

Establish guidance that requires the restoration and maintenance of banks along navigation channels.

I concur generally, although I would hate to see this recommendation used to justify maintaining channels that should in fact be closed. Think of the money and energy squandered for decades on MRGO!

10) Comparison of Process Efficiencies:

The Government Accountability Office (GAO) should be directed to conduct a study on the efficiency of various project implementation programs. The GAO should compare the efficiency and effectiveness of the Corps of Engineers regular construction program (Construction General), with the commands’ rebuilding efforts in Iraq and Afghanistan, the Coastal Wetlands Planning, Protection and Restoration Act program (Breaux Act), emergency work done within the 12 months period following Hurricane Katrina, locally-executed projects, and the federal highway program to identify the models that provide most efficient process for critical project execution in our state.

Again I plead ignorance of the issue and the specific meaning of the term “efficiency” as used here. In terms of engineering projects, efficiency should mean the functional value of the completed project over its lifetime divided by the combined total costs of engineering design, construction, operation and maintenance (including the negative environmental impacts of the project).   

Authority 3 comments:

Regarding the Interim Actions:  Elevating the NO District will do little or nothing other than promote incompetence–anyway I just don’t seeing it happen because it will upset the apple cart regarding Corps organization elsewhere. Extending the command might be helpful if the Colonel is highly competent, but counterproductive if he/she is a lemon.  Again, this is tilting at a windmill. Establishing guidance for the Deltaic Plan (3) is needed, but devil in the details. Ditto for streamlining NEPA review (4). This wish for a Transition Plan (5) may be  just postponement of difficult decisions and dealing with compassionate and financially assisted relocation.  On number 6, does this actually say “liberally?” I didn’t realize that word was in the vocabulary, other than in pejorative sense.  But seriously, is it reasonable to expect the Federal government to bear 65% or more of the costs of local projects that may be counterproductive or boondoggles without review and approval?  The last Interim Action of a GAO report may actually be a good idea.

Authority 4 comments:

NEPA “relax” is, inter alia, driven by Morganza, where what they are doing now is quite NEPA vulnerable;  if it is a matter of restoration projects, NEPA already has procedures for expedited review that have been implemented for NO levees with some success. The proposed notion of limiting NEPA review to a single pre-chosen alternative is exactly what the state did ewith its so-called Morganza review some time back, and was of course a charade. Jim Tripp (Chief Legal Counsel, Environmental Defense) has written on a way to expedite NEPA in restoration work.  

Len Bahr

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  39. To anonymous:

    Corp's money? By that would you be referring to the money the American people have provided to Congress to address the flood protection needs of Louisiana? Perhaps a more efficient use of said funding could be accomplished by a single purpose civilian public works agency, instead of a military agency with multiple priorities.

  40. Anonymous says:

    Corps of Engineers has spent billions of dollars in protecting New Orleans and/or Southern Louisiana. Many flood protection works are done with 100% Corps’ money. I am not sure any other Federal agency has this capability. If you want Corps to be out, be careful what you wish for.

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