Planning Guidance>Specific Study Guidance>Index of Issues

CECW-PM                                                                                                      7 May 2002

  

HQUSACE Policy Compliance Assessment

 Tanque Verde Creek, Pima County, Arizona, Draft Limited Reevaluation Report (LRR) July 2000 and Draft Environmental Assessment, October 2001

 

Table of Content for Issues:

 Section 104 Credit

 Mitigation Land

 Environmental Requirements

     Endangered Species

     Plan Selection/Environmental Benefits

 Economic Documentation Requirements

     Risk Analysis

     Benefit Estimation Technique

     Residential Structure Plus Land Value

     Environmental Damage Benefit

Authority

    (1) Project Implementation
    (2) Budget Authority

    (3) Special Cost Sharing

    (4) Basis for Federal Interest Described in 1986

 Real Estate Requirements

 Real Estate Appendix


1.  BACKGROUND.

 

a.  Study Area & Damage Problem.  The study area is six miles east-northeast of downtown Tucson.  This segment of Tanque Verde Creek (a tributary of the Rillito River) is approximately two miles long.  The average annual rate of bank erosion is 13 feet.  About 9,500 linear feet, located along four separate channel segments have previously been stabilized with soil cement to prevent streambank erosion.  The report cites expected annual erosion damages caused by floodflows as $714,100.

 

b.  Recommended Plan.  Two segments (4,220 feet and 2,830 feet) of new bank protection would be constructed along the south bank of Tanque Verde Creek.  Another segment of bank protection, about 1,550 feet long, would be constructed immediately upstream of the Craycroft Road Bridge along the north bank. The proposed action would affect desert riparian habitat.  The plan proposes acquisition of about 48 acres along the north bank to be designated a riparian habitat preserve.  The first cost of the project proposal $3,361,670 (at May 2000 prices) is to be shared Federal (65 percent) and non-Federal (35 percent).  Based on a 6.625 percent discount rate and a 50-year period of economic evaluation, the equivalent annual benefits are $714,000.  Equivalent annual costs are $239,800.  Net benefits are $456,400 and the ratio of benefits to costs is 2.8 to 1.  The ASA(CW) granted Pima County, the non-Federal sponsor, conditional approval for credit under section 104 of WRDA 86 to construct about 4,000 linear feet of soil cement bank protection along the south bank. 

 

2.  UNRESOLVED REVIEW COMMENTS.

 

a.  Section 104 Credit.

 

HQUSACE COMMENT 2e.   Section 104 Credit.  The plan implementation and cost apportionment section of the LRR generally described work eligible for credit.  The LRR will be the decision document that supports the PCA.  Therefore, additional information on the credit is needed in the LRR.  Describe all of the non-Federal work that is eligible for credit.  State costs for construction, LERRD and any betterments separately.  The sponsor gets credit for related LERRD as a LERRD contribution, not as a Section 104 credit.  The sponsor credits are specified by ER 1165-2-29.  The LRR should show the sponsor’s Section 104 creditable work in the cost apportionment table.  Also show the offsetting Section 104 credit in the Federal column. 

 

DISTRICT RESPONSE 2e: The report will be revised to show sponsor’s Section 104 creditable work in the cost apportionment table as indicated above. 

 

Table 7.1  Cost Apportionment Table

Tanque Verde Wash, AZ

Bank Erosion Control Project

 

Federal

Non-Federal

Total

Construction (Construction, S&A, E&D, Contingency)

3,066,060

 

3.066.060

104 Credit Construction

-2,099,300

2,099,300

 

Construction LERRDs (lands, easements, rights-of-way, relocations, and disposal sites)

0

295,610

295,610

Total Construction Cost

  (percentage of total cost)

966,760

(29%)

2,394,910

(71%)

3,361,670

 

Additional Cash to Provide Minimum 35% Non-Federal Share

+1,218,326

-1,218,326

 

Total Cost Shared Amounts for Construction, Lands, and Additional Costs

  (percentage of total cost)

2,185,086

(65%)

1,176,584

(35%)

3,361,670

 

Total First Costs

2,185,086

1,176,584

3,361,670

 

 

HQUSACE ANALYSIS 2e: The concern is not resolved.  The above report revision does not fully resolve the concern on clear documentation of the sponsor’s Section 104 creditable work.  The subject report will serve as the decision document for Congressional construction authorization and for the PCA.  Accordingly, the report (including its REP) should clearly describe the proposed Federal project including the Section 104 component, its estimated cost, and the parties implementation responsibilities.  Neither the report nor the REP clearly describes the Section 104 component of the project.  Therefore, the review team is not able to determine whether the REP includes all real estate requirements or just those that pertain to the portion of the project to be constructed by the Government.  In addition, the REP still retains descriptions of several different alternatives, which leads to confusion on what is to be implemented and the associated LERRD requirements and values. 

 

According to the table the estimated total first cost is $3,361,670.  Federal cash in the amount of $1,218,326 would be provided as the credit reimbursement to the non-Federal sponsor so that the non-Federal contribution of construction and LERRD’s is reduced from 71% to 35%.  The non-Federal current and future work potentially eligible for 104 credit amounts to $2,099,300.  The table in the response should be revised to document and explain the non-Federal creditable work.  Clarify, if there are any non-Federal LERRD’s in the $2,099,300 item for 104-credit construction.  Also the report needs to provide a breakout of the current and future eligible work eligible for credit.

 

DISTRICT RESPONSE TO HQUSACE ANALYSIS 2e: 

 

Section 104 Component:  Chapter VII, Section D.  “Current and Future Work Eligible for Credit” of the LRR will be expanded to describe in more detail the components of the project that are candidate for Section 104 Credit.  Additionally, the revised costs apportionment table (shown below) should aid in clarifying cost-sharing responsibilities.

 

Description of Several Alternatives in the REP:  The REP has been revised to eliminate references to the preliminary alternatives found in Section 5 of the REP.  This section has been modified to include only the description of the selected/recommended plan and its associated costs.   The Revised REP is enclosed at the end of this file/document.   

 

Revised Cost Apportionment Table 7.1:  This table has been updated to reflect cost sharing requirements in accordance with ER 1165-2-29.  Appropriate changes were made to reflect the proper breakdown of construction and LERRDS costs.  Furthermore, LERRDS costs associated with construction and mitigation measures were separated accordingly. 

 

Table 7.1  Cost Apportionment Table

Tanque Verde Wash, AZ

Bank Erosion Control Project

 

 

 

 

TPC Apportionment Before Consideration of Section 104 Credit

Feature

Federal

Non-Federal

Total

Construction Costs

 

 

 

South Bank (Note 1)

$1,873,578

 

$1,873,578

North Bank

$411,922

 

$411,922

LERRDS Costs

 

 

 


Continued