Draft rules, a draft environmental impact statement, and projects whose scope and impacts remain inscrutable to all but the contractors and their government supervisors.
That, in a nutshell, describes the nature of the work being done in Hilo in the wake of the great flood of November 2000 under the U.S. Department of Agriculture’s Emergency Watershed Protection (EWP) Program. And not only in Hilo, but at hundreds of other flood sites around the country.
Altogether, the program, managed by the Natural Resources Conservation Service, spends about $100 million annually. Since its inception more than 20 years ago, the total expenditures easily run into the billions of dollars. And this by a program that, by rights, and by the USDA’s own rules, should not be spending a penny until at least 30 days after its draft EIS is made final.
Odds are, at least some of that money is being spent on worthwhile projects. But of the dozen Hilo projects, more than one would seem to be of dubious value, even by the NRCS’ own standards – to the extent, that is, such standards are possible to know.
First a word about the way the NRCS justifies its EWP projects. After a flood occurs, if the local government – Hawai`i County, in this case – seeks help from the NRCS, the agency responds by sending its engineers and other staff to the area of the flood. Those sites where floodwaters damaged structures or created hazards are evaluated. When it seems likely to NRCS staff that a site might qualify for remedial work under EWP, a more detailed damage survey report, or DSR, is prepared.
The DSR is intended to provide NRCS with a cost-benefit evaluation used to justify the project or reject it. In the DSR, the value of houses or other structures in jeopardy is estimated and is then multiplied by the fractional damage that might be done from a similar flood in the future. For example, if a project protects a $100,000 house from damage that might otherwise cost $20,000, to be justified, the project should cost no more than $20,000. After the potential damage is calculated, the cost of the project is estimated and the ratio of benefit to cost is then calculated. If the project is to be done, that ratio has to be equal to or greater than one.
This formula is biased toward protection of higher value houses and structures than those of low value. Doug Toews, in charge of EWP projects for the Hawai`i office of the NRCS, explains that the program does allow for special considerations in areas deemed to be economically disadvantaged. But, he adds, “Hilo doesn’t qualify” for that.
Not to worry, though – at least on that account. The damage survey reports that justify some of the Hilo projects show houses valued at levels far in excess of the most upbeat real estate agent’s wildest dreams.
The effect of that is to skew the NRCS’ benefit-cost ratio in a direction that favors moving forward with projects that may be marginal if more realistic values were assigned to the properties being protected. Yet the NRCS’ Toews denies that his agency is on a mission to spend funds without adequate justification. “We didn’t adjust values simply to make projects qualify,” he told Environment Hawai`i. Many more projects were considered than were ultimately approved, he said.
The DSRs were done in haste, he added. Assessments of housing values were made by out-of-town staff. No effort was made to check the values in the DSRs against more meaningful benchmarks, such as assessed valuations in the county property tax office or recent sales of comparable houses.
Urban Flood
Komamala Gardens is a moderately upscale subdivision with underground utilities, broad streets, and sidewalks. It was developed in the late 1970s on a tract of land running alongside the Waiakea River. When the first flood insurance rate maps were drawn up a few years later, the entire subdivision fell into the zone that would be underwater during a 100-year flood.
On the whole, the drainage system put in place by the developer worked well in November 2000. On the mauka (upland) side of the subdivision, levees defended houses against the main channel of the Waiakea. Most problems centered on a drainage ditch carved through the center of the subdivision. That became what is referred to now as a tributary of the Waiakea. At the point the tributary met the main channel, one house was inundated with up to three feet of water. It and several other houses were evacuated.
Most recent housing sales in Komomala Gardens are in the range of $200,000, with houses in the lower-elevation areas priced at the lower end of the range. Yet the damage survey report for four damaged or threatened houses in the subdivision put the value of each house at $300,000. Altogether, the DSR estimated that the near-term damage reduction resulting from a flood-control project on the stretch of Waiakea Stream near the houses would be $393,000. The cost of work that the NRCS proposed to do came to $313,000, for an overall favorable benefit-cost ratio of 1.26. (As benefit-cost ratios go, this one is thinner than most. Some projects proposed for Hilo had ratios as high as 6.33 and 5.25, although most hovered around 2.5 or 3.)
In other words, had the houses been valued at a figure closer to the market value, the project would have been a no-go.
In this particular case, not only were the houses over-valued, the cost of the project was under-valued, with the effect again being to beef up the benefit-cost ratio.
In the cost estimates done for all other Hilo projects, the cost of a cubic yard of CRM wall, the type of wall used to line eroded stream banks, is given at $600. Yet in the estimate of costs for the Komomala Gardens project, the unit cost for a cubic yard of CRM wall is given at half that – or $300.
As a result, the cost of the project comes to $313,000, with $240,000 of that reflecting the cost of 800 cubic yards of CRM wall. Had the CRM wall been assigned the $600-per-cubic-yard cost used in all other cost estimates, the total cost of the project would have been $553,000. The benefit-cost ratio would have been below 1.0, and the project would have been declared a no-go.
Toews could not explain the difference in estimated cost of a cubic yard of CRM wall used in calculating this project. But he strongly denies there was any effort to cook the books in order to justify this or any other given project.
Saving a Swimming Pool
Where Waiakea Stream passed under Kawailani Street, the November floods wiped out portions of a retaining wall installed along the stream to increase the number of houselots in the adjoining subdivisions. The November 2000 flood washed out a portion of that wall and floodwaters spilled into the yards of about 10 houses on either side of the stream.
A damage survey report estimated the value of private property to be protected by a flood control project at $555,000. Among properties to be protected was a house with private swimming pool immediately neighboring the stream. The value of that one house was placed at $200,000, while other houses were assessed at between$150,000 and $190,000.
The repairs were recently completed. Grass has been newly planted in the yard of the house with the pool, and a new retaining wall, topped by a chain-link fence, is in place.
Toews was asked about the use of public funds to assist families that could or should be able to afford private insurance. “The EWP program has been criticized by some of our own people from that standpoint,” he said. “We’re basically subsidizing people who want to live along creeks and streams.”
The EWP program as a whole is being changed to address these concerns, he added. The purchase of properties in flood plains, or of flood-plain easements preventing development, is already allowed for rural areas served by the program, he said. “We’re moving toward allowing flood plain easements for urban areas as well.”
Environmental Impacts?
Under the National Environmental Policy Act, and under the USDA’s own rules, programs such as the Emergency Watershed Protection program must be done under terms and conditions set by an environmental impact statement. In 1998, some 20 years after the program began, the USDA announced it would begin preparing a draft programmatic environmental impact statement. In December 1999, the document was made available for public review and comment.
Two years later, the document is still in draft form, with no record of decision or final EIS ever being adopted by the NRCS.
Because the document remains in draft form, it is difficult to know the nature of comments received. However, the Environmental Protection Agency summarized its comments in a Federal Register notice on March 24, 2000. The EPA “expressed concern that the ‘Prioritized Watershed Planning and Management’ alternative was not selected as the proposed action. EPA requested several modifications to the proposed program, including requirements for cumulative impact assessment and greater use of bioengineering principles when designing projects.”
Bioengineering, as its name suggests, is a softer approach to flood-control projects than the traditional approach of channelizing stream beds and armoring banks. Examples include acquisition of flood-plain easements, planting of stream banks prone to erosion, and stabilization of stream banks with more gentle slopes that might allow them to be vegetated.
But as the Hilo projects show, the NRCS continues to prefer old-fashioned brick-and-mortar approaches to flood control. And to date, the county Department of Public Works, the cooperating agency for the urban projects, has gone along with the approach.
All that might change should the county adopt the latest draft of the Hawai`i County General Plan, now undergoing revisions. In the chapter on flood control and drainage, draft language calls on the county to “develop drainage master plans from a watershed perspective that considers non-structural alternatives, minimizes channelization, protects wetlands that serve drainage functions … and encourages the establishment of floodplains as public green ways.” And, the plan continues, “where applicable, natural drainage channels shall be improved to increase their capacity with special consideration for the practices of proper soil conservation and grassland and forestry management.”
— Patricia Tummons
Volume 12, Number 7 January 2002
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