DOCKET N0.

65-2002-36151

STATE OF MINNESOTA
OFFICE OF ADMINISTRATIVE HEARINGS

FOR MINNESOTA DEPARTMENT OF NATURAL RESOURCES

In the Matter of the Dam Safety and Public REPORT OF LARRY J. PRATHER
Waters Work Permit No. 2018-0819 for the
Fargo-Moorhead Flood Risk Management
Project, Clay and Wilkin Counties,
Minnesota, and Cass and Richland
Counties, North Dakota

Background and Qualifications

My name is Larry J. Prather. I am an Economist and a retiree of the U.S. Army Corps

of Engineers ("USACE" or "Corps"), where over the course of a 30-year career I served in

various capacities, including Senior Policy Advisor in the Policy and Planning Division;

Assistant Director of Civil Works (Legislation and Planning); and Chief, Legislative

Management. My experience and qualifications, along with my contact information, are

attached as Exhibit A.

I have not testified as an expert or by deposition during the previous four years. I have

not authored publications in the previous ten years. I am being compensated for my time in

preparing this report and for providing written or oral testimony at the rate of $150 per hour,

plus expenses.

Statement of Opinions and the Basis and Reasons for Them

I. Benefit-Cost Analysis and the Public Welfare in Flood Control Decisions

In the Flood Control Act of 1936, Congress "recognized that destructive floods upon

the rivers of the United States ... constitute a menace to national welfare ... [and] that the
Federal Government should improve or participate in the improvement of navigable waters or

their tributaries, including watersheds thereof, for flood-control purposes if the benefits to

whomsoever they may accrue are in excess of the estimated costs .... " 33 U.S.C. § 701a

[emphasis added]. This statement is generally recognized as enshrining benefit-cost analysis

as the principal component of expressing national welfare when making policy, project or

regulatory decisions. In fact, benefit-cost analysis has been the dominant indicator of welfare

in evaluating single-purpose flood control projects like the Fargo-Moorhead diversion.

Over many decades since the 1936 Act, the technique of benefit-cost analysis has been

refined. The current expression of U.S. policy on benefit-cost analysis applied to water

resources projects is found in the Economic and Environmental Principles and Guidelines for

Water and Related Land Resources Implementation Studies ("Principles and Guidelines"),

approved by President Reagan. The key provision of this policy is the Federal objective: "The

Federal objective of water and related land resources project planning is to contribute to

national economic development consistent with protecting the Nation's environment, pursuant

to national environmental statutes, applicable executive orders, and other Federal planning

requirements." Principles and Guidelines, page iv.

The Principles and Guidelines also provides this directive for selecting among

alternative plans to solve a water resources problem like flooding in the Fargo and Moorhead

area:

A plan recommending Federal action is to be the alternative plan

with the greatest net economic benefit consistent with protecting
the Nation's environment (the NED plan), unless the Secretary of
a department or head of an independent agency grants an
exception to this rule. Exceptions may be made when there are

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 overriding reasons for recommending another plan, based on
other Federal, State, local and international concerns.
Id. at page v.

The project selection rule makes clear that the primary metric of welfare in selecting a flood

control plan is national economic development. The net benefit principle is more than a mere

investment criterion.

Countries around the world use benefit-cost analysis to evaluate the welfare

contributions of projects. The World Bank requires such analysis for projects that it finances.

States often use benefit-cost analysis. A US Department of Transportation Report, entitled Use

of Benefit-Cost Analysis by State Departments of Transportation: Report to Congress,

responding to a request in Senate Report 113-182 included the following: "Minnesota DOT

(MnDOT) regularly uses BCA and is often cited as a national leader in the use of BCA (Benefit

Cost Analysis). In addition to MnDOT, the DNR also acknowledges the importance of projects

having benefits in excess of costs if permits are to be feasible. In fact, Minnesota DNR Fargo-

Moorhead Final Supplemental EIS, Appendix B, page 6, lists as an assumption:

Minnesota Permitting Feasibility. Any alternative that would not offer benefits
to the state that are commensurate with the impacts to the state would be
unable to be permitted in Minnesota. This is because such an alternative
wouldn't represent the least impactful solution in Minnesota (as required by
Minnesota Law), and thus it would be infeasible.

This statement evidences the DNR's requirement that benefits of public waters projects be

commensurate with the impacts. In addition, it demonstrates the importance of a favorable

quantification of benefits and impacts to permitting feasibility. By common usage, two things

are commensurable if they are measurable or comparable by a common standard. Measurement

and quantification are central to determining that benefits are commensurate with impacts or

costs. Benefit-cost analysis is the best available tool for making such a finding.

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 II. Benefit-Cost Analysis of the Fargo-Moorhead Diversion

Finding 421 of the Minnesota DNR, Findings of Fact, Conclusions and Order of the

Commissioner, December 27, 2018, at page 76, reports:

The Federal EIS shows an overall NED Benefit Cost Ratio (BCR)
of 1.76 based on a project cost of over $1.7 billion on the 2016
Project, average annual benefits of over $174 million, and
average annual costs of over $100 million. See Federal EIS at ES-
15. The State FEIS did not calculate a NED (National Economic
Development) BCR (Benefit Cost Ratio). On August 1, 2016 the
State's consultant, Alexander Aaron, Inc., calculated a NED BCR
of0.58 using the Federal fiscal year 2016 discount rate and AAD
(average annual damage) reduction in benefits of $41 million
derived from FEMA's HAZUS model. The State analysis did not
account for the increase in estimated project costs from $1.7
billion to $2.2 billion, which would decrease the BCR to less than
0.50. Using the methodology of the State's consultant, the 2016
Project's costs outweighed its benefits. 1

Finding 422 continues:

The Federal BCR for the 2016 Project incorporates benefits that
are provided by the current flood risk reduction project plus
emergency measures in the F-M metropolitan area. The Federal
BCR does not break out the "added value" created by the
proposed Project from the value provided by existing permanent
flood risk reduction plus emergency measures. Thus the Federal
BCR overstates the incremental benefits of the 2016 Project
because a number of benefits that are claimed as project benefits
are currently provided by present flood risk reduction plus
emergency measures and are not added benefits of the proposed
_2016 Project.

Id.

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Here, the State's benefit-cost analysis rests on a project cost of $2.2 billion. The BCR is
adjusted downward from the consultant's 0.58 to 0.5. The project costs in 2018 were actually
$2.75 billion based on information currently posted on the Diversion Authority's website.
Using the accurate $2. 75 billion estimate would doubtless decrease the 2018 BCR even further
below 0.5. For the cost estimate in 2018 see: "How much will it cost?",
https://fmdiversion.gov/about-the-project/ (accessed, January 30, 2020)

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 The DNR accepts the report and conclusions of the State's consultant in developing its

findings in both the 2016 ("Plan A") and 2018 ("Plan B") permit evaluation. The State's

estimate of benefits is computed using a FEMA model. The State's analysis shows that the

Fargo-Moorhead Diversion fails to be economically justified.

In the Plan B Findings ofFact, Conclusions and Order ofthe Commissioner, December

27, 2018, the Commissioner concludes in Finding 423:

The USACE did not revise its BCR for the 2018 Revision.
Minnesota Rules Ch. 6115 does not require that DNR evaluate
the public welfare using a cost benefit analysis. The cost benefit
analysis helps allocate public investment efficiently, and is not
necessarily utilized as a public welfare metric. The Governors'
Task Force recognized that the F-M metropolitan area is a
regional economic hub and significant damage to the F-M
metropolitan area would have negative repercussions on future
economic growth, business expansion, job creation, and social
vitality of the region. See Task Force Report at 9. The DNR
concludes, therefore, that the Revised Project may prevent these
negative consequences to the economic and social welfare of the
reg10n.

Therefore, in the 2018 ("Plan B") analysis the Commissioner rejected his own

unfavorable benefit-cost analysis (BCR = .5) in evaluating the quantifiable welfare

contributions of Plan B. The DNR concludes the "Revised Project may prevent these negative

consequences to the economic and social welfare of the region." Id. [emphasis added]. The

"negative consequences" or "negative repercussions" are cited as being captured in the

Governor's Task Force Report: "The Governors' Task Force recognized that the F-M

metropolitan area is a regional economic hub and significant damage to the F-M metropolitan

area would have negative repercussions on future economic growth, business expansion, job

creation, and social vitality of the region. See Task Force Report at 9."

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 Examination of the Governors' Task Force Report at page 9 provides only the

statement of Governor Dayton as follows:

Reliable and effective flood protection for the cities of Moorhead

and Fargo and their surrounding regions is essential. It is a
prerequisite for successful future economic growth, business
expansion, job creation, and social vitality. Yet it cannot come at
the excessive sacrifice of other people's lands, lives, and
livelihoods. For a project of this magnitude and complexity, those
considerations are also essential.

Finding 423 does not present any quantified regional benefits information to support

the welfare finding or Governor Dayton's statement. While alternative flood control projects

might favor development at one location over others in the region, the expectation should be

that economic activity will continue to grow and expand within the region but merely at

different nearby locations. Unless the project can be shown to have significant regional

impacts within Minnesota, it is difficult to understand how the regional impact calculus of the

Commissioner is compelling evidence for asserting positive welfare effects within the State.

In fact the DNR Commissioner's finding of welfare contribution in Finding 423, i.e. "that the

Revised Project may prevent these negative consequences to the economic and social welfare

of the region" is a weak assertion of a welfare contribution and runs counter to the DNR' s

findings in Findings 136 and 137 for the Plan A permit as discussed below.

The Commissioner's finding that the Governor's recognition that flooding has

"negative repercussions" justifies a finding that Plan B meets the welfare criteria of the State

of Minnesota ignores the negative welfare implications of the benefit-cost analysis and ignores

that coherent welfare finding must integrate both the benefits and costs of a project or policy.

If this argument is sufficient for an affirmative welfare finding, then any flood control project,

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regardless of costs, benefits or impacts, will pass the State's welfare threshold merely because

it "prevents floods" and associated "negative repercussions."

III. Inconsistencies Between Benefit-Cost Analyses Regarding Plan A and Plan B

Equally important to this evaluation is the DNR' s use of essentially the same economic

data to support the denial of the permit for Plan A in 2016 - an inconsistency that calls into

question whether the agency's actions may be arbitrary and capricious. I now refer to the Plan

A Findings of Fact beginning at finding 131:

131. The Federal EIS shows an overall National Economic Development (NED)
BCR of 1. 76 based on a project cost of over $1. 7 billion, average annual benefits
of over $174 million, and average annual costs of over $100 million. Federal
EIS at ES-15. The State FEIS did not calculate a NED BCR. On August 1, 2016
the State's consultant, Alexander Aaron, Inc., calculated a NED BCR of 0.58
using the Federal fiscal year 2016 discount rate and AAD reduction in benefits
of $41 million derived from FEMA' s HAZUS model. The State analysis did not
account for the increase in estimated project costs from $1.7 billion to $2.2
billion, which would decrease the BCR to less than 0.50. The project costs
outweigh the benefits. [The same as Finding 421 in the Plan B, 2018 analysis]

132. The Federal BCR for the proposed Project incorporates benefits that are
provided by the current flood control project plus emergency measures in the F-
M metropolitan area. The Federal BCR does not break out the "added value"
created by the proposed Project from the value provided by existing permanent
flood control plus emergency measures. Thus, the Federal BCR is misleading
because a number of benefits that are claimed as Project benefits are currently
provided by present flood control plus emergency measures and are not added
benefits of the proposed Project.

136. The Regional Economic Development (RED) analysis prepared by the

Diversion Authority for the Project takes into account the regional economic
activity that results from each alternative plan, using projections of income,
employment, output, and population. The RED benefits for the Project were
calculated using the IMPLAN@model. The analysis finds an annual economic
benefit of 14,715 jobs and $491 million in labor income attributable to
construction and implementation of the Project. State FEIS, App. I at 50. The
vast majority of these jobs and labor income would occur during the eight year
Project construction duration and are not permanent. They would accrue to the
F-M metropolitan area for any construction project of this magnitude and cannot
be attributed to the long term operation and maintenance of the Project. The total
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 economic impact associated with operation and maintenance of the proposed
Project (i.e., those considered permanent jobs) are estimated at 3 7 jobs and $2
million in labor income. State FEIS, App. I at 50.

137. The review of the economic analysis and flood control benefits
performed for the proposed Project does not establish that the quantifiable
benefits support the need for the Project as required by Minn. R. 6115.0410,
subp. 8C (2014). Additionally, the permanent economic benefits attributed to
the proposed Project do not contribute to the public welfare in a meaningful
way. Minn. Stat.§ 103G.315, subp. 3. Constructing a Class I (high hazard) dam
is neither reasonable nor practical in light of the incremental increase of flood
protection afforded to existing development in the F-M metropolitan area. Minn.
Stat.§ 103G.315, subd. 3 (2014).

Minnesota DNR, Findings of Fact, Conclusions and Order of the Commissioner,

October 3, 2016, page 36-37.

The DNR findings 132 and 136 in the Plan A analysis are in stark contrast to Finding

423 in the Plan B analysis. Using the same data, with projects nearly identical in terms of

economics and flood protection, (Plan A and Plan B), the DNR reaches diametrically opposed

conclusions related to the contributions of flood diversion at Fargo-Moorhead. In the Plan A

analysis, the conclusion is

The permanent economic benefits attributed to the proposed

Project do not contribute to the public welfare in a meaningful
way. Minn. Stat. § 103G.315, subp. 3. Constructing a Class I
(high hazard) dam is neither reasonable nor practical in light of
the incremental increase of flood protection afforded to existing
··<levelopment in· the F-M metropolitan area. Minn. Stat. §
103G.315, subd. 3 (2014).

The DNR also concludes at Finding 136 of the Plan A analysis that the paucity of regional

benefits is not persuasive in compelling a different conclusion.

Thus, guided by the same statutes and regulations, the Minnesota DNR uses essentially

identical economic benefit-cost analysis, compares two projects that are essentially the same

in their overall economic impact and flood control contribution and reaches different,

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diametrically opposed conclusions in the two analyses. This raises serious questions about

whether the DNR has followed its own code of regulations in one of these cases or questions

as to what the State's metrics are for determining welfare. The analysis in the case of Plan A

would appear to hew closer to common usage and convention than the analysis in Plan B.

Summary

Review of the deployment of benefit-cost analysis in the two permit applications (2016

and 2018) discloses the following conclusions:

• Independent and credible benefit-cost analysis produced by the DNR finds that the
project has a BCR of about .5 which is far below the level that would be consistent
with favorable welfare findings in nearly all venues where benefit-cost analysis is
used. Based on the benefit-cost analysis embraced by the DNR, the project has net
negative welfare implications.

• The DNR uses the same information related to benefits and costs, applied to projects
with essentially identical flood protection, benefits, and costs, and under the same
State regulations and statutes, to reach opposite findings of welfare for Plan A and
Plan B.

• The DNR' s rejection of its own benefit-cost analysis in its Plan B finding is
tantamount to a rejection of its own statutory and regulatory requirements to quantify
contributions to the State's welfare. This conclusion is amply demonstrated in how
the DNR relied on that analysis as a sufficient expression of quantitative welfare in its
Plan A permit denial.

• The DNR relies instead on a brief statement of Governor Dayton, cited on page 9 of
the Governors' Task Force Report, that the Plan B project may prevent unquantified
adverse impacts on the regional economy. This evidence is not only unquantified but
ignores the costs and other impact to Minnesota's welfare.

• Under the standard adopted in the Plan B Findings, any flood control project could be
approved merely on the basis of its preventing floods and associated "negative
repercussions."

• Based on these considerations, the DNR has not adequately demonstrated that Plan B
promotes the public welfare consistent with its statutes and codified rules.

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Materials Reviewed

The following documents were reviewed as part of my preparation in compiling this

report:

• The 2016 ("Plan A") Findings of Fact, Conclusions, and Order ("Findings of Fact").
The Plan A Findings of Fact are already in possession of the parties, and can also be
found at:

https://files.dnr.state.mn.us/waters/surfacewater section/damsafety/fargo moorhead-

findings of fact.pdf

• The 2018 ("Plan B") Findings of Fact, Conclusions, and Order ("Findings of Fact").
The Plan B Findings of Fact are already in possession of the parties, and can also be
found at:

https://files.dnr.state.nm.us/waters/surfacewater section/damsafoty/fargo moorhead-

fof-2018.pdf

• The 2011 USACE Final Feasibility Report and Environmental Impact Statement
("FEIS"). The FEIS is already in possession of the parties, and can be also found at:

https://fmdiversion.com/pdf/CorpsReports l /Main Report with Attachments.pdf

• The 2013 USACE Supplemental Environmental Assessment ("2013 EA"). The 2013
EA is already in possession of the parties, and can be found at:

https://cdm 16021.contentdm.oclc.orn/digital/collection/p 16021 coll7 /id/3 75/rec/2

• The DNR's 2016 Draft and Final Environmental Statements. These are already in
possession of the parties, and can also be found at:

https://vvww.dnr.state.11111.us/input/environmentalreview/fm flood risk/seis.html

• The 2016 Alexander Aaron, Inc. report on benefit/cost ratio commissioned by the DNR.
This report was referenced in both the Plan A and Plan B Findings, and is available for
review from the DNR.

• The 2018 Fargo-Moorhead Area Flood Diversion Task Force: Final Report and Report
Appendix ("Task Force Report"). The Task Force Report is already in possession of
the parties, and can also be found at:

https://www.clnr.state.mn.us/waters/watermgrnt section/fargo-moorhead-task-
force/inclex.html

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• The DNR' s 2018 Draft and Final Supplemental Environmental Impact Statements.
These are already in possession of the parties, and can also be found at:

https://www.dnr.state.rnn.us/input/environmentalreview/fm flood risk/seis.html

• The 2018 USACE Supplemental Environmental Assessment ("EA #2"). EA #2 is

already in possession of the parties, and can be located at:

https://www.mvp.usace.armv.mil/FMM FRM/

• 2012 USACE Memorandum on Methodology for Updating Benefit-to-Cost Ratios

(BCR) for Budget Development. This memorandum can be found at:

https://planning.erdc.dren.mil/toolbox/librarv/MemosandLetters/CWPMl2-00J .pdf

• The USACE's Economic and Environmental Guidelines for Water and Related Land
Resources Implementation Studies. These guidelines can be found at:

https://planning.erdc.dren.rnil/toolbox/guidance.cfm?Id=269&0ption=Principles%20
and%20Guidelines

• The USDOT's Use of Benefit-Cost Analysis by State Departments of Transportation:

Report to Congress. This report can be found at:

https://www. fhwa.clot.u.ov/policv/otps/pubs/senate bca report 05172016 revised.pelf

Exhibit List

The following documents may be used as exhibits during my testimony:

• The 2016 ("Plan A") Findings of Fact, Conclusions, and Order ("Findings of Fact").
The Plan A Findings of Fact are already in possession of the parties, and can also be
found at:

https://files.dnr.state.mn.us/waters/surfacewater section/damsafetv/faru.o moorheacl-

findings of fact.pdf

• The 2018 ("Plan B") Findings of Fact, Conclusions, and Order ("Findings of Fact").

https://files.dnr.state.11111.us/vvaters/surfacewater section/damsafetv/fargo moorhead-

fof-2018.pclf

• The 2016 Alexander Aaron, Inc. report on benefit/cost ratio commissioned by the DNR.
This report was referenced in both the Plan A and Plan B Findings, and is available for
review from the DNR.

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• The DNR's 2018 Draft and Final Supplemental Environmental Impact Statements.
These are already in possession of the parties, and can also be found at:

https://www.dnr.state.nrn.us/input/environmentalreview/fm flood risk/seis.html

• The 2018 Fargo-Moorhead Area Flood Diversion Task Force: Final Report and Report
Appendix ("Task Force Report"). The Task Force Report is already in possession of
the parties, and can also be found at:

https://www.dm.state.nm.us/waters/watermgmt section/fargo-moorhead-task-
force/index.html

The above report summarizes my opinions and the basis and reasons for them as of

the date of the report. I understand that discovery is not complete and additional reports and

written testimony will be forthcoming. I reserve the right to supplement my opinions as

additional information becomes available.

Dated: February 3, 2 02 O

Larry J. Prather

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 Resume

Larry Prather
US Army Corps of Engineers, Retired
PO Box 1311, Middletown, Maryland 21769 larry.j.prather@gmail.com 240-772-7056

Summary: Transportation, natural resources, economics and environmental professional

with 35 years experience directing public planning, policy and intergovernmental relations
organizations that have achieved dramatic results and benefits.

Experience:

Senior Policy Advisor, Policy and Planning Division

US Army Corps of Engineers
July 2012 - Retirement (2 years 5 months) I Washington, D.C.

Principal senior policy liaison to the American Association of Port Authorities. Co-chairman of
the AAPA-Corps Quality Partnership Work Group on Legislative Authorities. In this role,
achieved substantive improvements to Corps legislative authorities including elimination of
the reconnaissance study and expansion in authorities that empower non-Federal entities
(port authorities, states and localities) to lead the design and construction of projects.
Principal liaison to the National Governors Association, the US Conference of Mayors,
National league of Cities and the National Association of Counties. Presentation on panel
with Ambassador Kirk to the Exports and Ports Task Force of the US Conference of Mayors
Annual Meeting in Dallas in June 2014. Led port orientation tour for National Governors
Association Staff to MPA's Port of Baltimore in August 2014. Prepared the plan for listening
sessions (webinars) to receive public input for implementing the Water Resources Reform
and Development Act of 2014. Contributed input to implementation plan for Sections 1001
and 1002 of the bill that significantly reform the Corps planning process.

Assistant Director of Civil Works (Legislation and Planning)

US Army Corps of Engineers
January 2004 - July 2012 (8 years 7 months) I HQ, US Army Corps of Engineers, Washington, D
Led development of water resources policy and legislation. Maintained alliances with state,
interstate and nongovernmental organization. Worked with congressional water policy
committees. Served as principal senior policy liaison with the American Association of Port
Authorities and as member of the Association's Harbors and Navigation Committee. Worked
with the Texas Water Development Board to get significant new water resources authorities
in the Water Resources Development Act of 2007.

EXHIBIT
1 j
B
Chief, Legislative Management
US Army Corps of Engineers
July 1998 - January 2004 (5 years 7 months} I HQ, US Army Corps of Engineers,
Washington, DC

Directed the Corps legislative program, Congressional testimony and legislative drafting
services. Supervised five professional and one administrative staff. Accomplishments:
Directed development of Chief of Engineers legislative proposals for the Water Resources
Development Acts (WRDAs} of 1999 and 2000. Principal Corps negotiator for WRDAs '99 and
2000 that together authorized over $13.2 billion in Corps activities. WRDA 2000 included the
Florida Everglades, the world's largest environmental restoration project. WRDA 1999
included the innovative programmatic authority for harmonizing the environment and flood
mitigation, Challenge XXI.

Chief, Policy Guidance Branch

US Army Corps of Engineers
July 1996 - July 1998 (2 years 1 month} I HQ US Army Corps of Engineers, Washington, DC

Directed development of policy guidance for navigation, flood damage reduction, ecosystem
restoration and coastal protection. Supervised four professional and one administrative staff.
Major accomplishments: First engineer regulation or formal policy on the Corps ecosystem
restoration program. Established a strategy to consolidate Corps policy and initiated
implementation. Directed Corps cultural resources program including archaeology, Native
American Graves Protection and Repatriation Act. Received award from the Department of
Justice for service as member of the Kennewick Man Team assembled to address disposition
of 9000+ year old remains found on the Columbia River, Washington. Led staff support of
Chief of Engineers Environmental Advisory Board. Overlaps leadership of Legislative
Management Branch during a dual assignment.

Chief, Planning Division

US Army Corps of Engineers
April 1995 - June 1996 (1 year 3 months} I US Army Engineer District, Pittsburgh,
Pennsylvania

Directed the district's planning program including economic analysis and environmental
compliance under the National Environmental Protection Act, Fish and Wildlife Coordination
Act and the Endangered Species Act. Supervised a staff of 40 supervisory and non-supervisory
professional, technical, and support personnel ranging in grade from GS-4 to GS-13. Met GI
Program execution goal for fiscal year 95; first time goal met in 5 years. Conducted first
successful Reconnaissance Review Conference in District; developed first cost shared
feasibility study. Established effective new partnership with Office of Surface Mining, States
of PA and WV to pursue ecosystem restoration. Collaborated with local and Congressional
interests in Pennsylvania and West Virginia to secure enactment of innovative flood damage

2
reduction authority in the Water Resources Development Act of 1996. Restructured division
to more effectively support environmental and cultural resources for ongoing design and
construction projects. Improved relationships with the Pennsylvania State Historic
Preservation Officer to expedite critical navigation and flood damage reduction projects.

Chief, Navigation Planning Branch

US Army Corps of Engineers
August 1989 - April 1995 (5 years 9 months) I US Army Engineer Division, Ohio River,
Cincinnati, Ohio

Provided overall leadership, direction, and management of the Ohio River Division Navigation
Planning Program. Supervised 4 professional and one administrative staff. Directed
navigation studies, systems analysis, economic analysis and allied studies, and preparation of
Congressional authorization documents by four district offices and the division office.
Formulated and managed the budget process to support this program. Exercised staff
oversight of the Ohio River Division Navigation Planning Support Center. Member of the
Navigation Design Oversight Team in Ohio River Division Headquarters. Major
Accomplishments: Led highly successful completion of reports and analyses (including
Washington level review) supporting Congressional authorization and funding of over $4
billion of navigation projects.

Executive Officer, 47th Field Maintenance Squadron

United States Air Force
August 1972 - August 1975 (3 years 1 month) I Laughlin AFB, Texas

Squadron Section Commander and Chief of the Administrative Services Unit (Orderly Room) --
responsible for health, welfare and morale of 450 assigned personnel

Contract Work

D.R. Reed and Associates, Study of Traffic Projections, National Navigation System, 2016-2017
Battelle National Labs, Independent Review, Norfolk Harbor Improvement Report, 2017-2018
David Miller & Associates, Review of Economic Analysis, Section 203 Civil Works Projects, 2019-
2020
Buffalo Red River Watershed District, Review of Fargo-Moohead Diversion, 2019-2020

Articles

With Dan Delich, "More federal regulation is not the answer to flooding," The Hill, November 2,
2017
With Dan Delich, "In flood resilience debate, there are no solutions - only tradeoffs," The Hill,
February 02, 2019

3
Publication

With Herb Wise, "Economic Analysis for Long-Term Operation and Maintenance of a Waterway:
The Case of the Monongahela River," Transportation Research Record 1222, Transportation
Research Board, National Academies of Science, Washington, D.C., 1989

Presentations

With Norm Starler, "Benefit Cost Analysis and Water Resources Planning Guidelines: Policy and
Practice," Society for Benefit-Cost Analysis, Annual Meeting, Washington, D.C. , 2009
With Norm Starler, "Revising the Principles and Guidelines for Water and Land Related
Resources Planning," Society for Benefit-Cost Analysis, Annual Meeting, Washington, D.C.,
2011

Volunteer

Knights of Columbus, Council 1622, Frederick, Maryland

Catechist, Holy Family Catholic Community
Hogan for Governor, 2014
Republican Committee, Adams Country, Pennsylvania, 2016

Education

Rice University, Houston, Texas

All But Dissertation, PhD, Economics
1975-1977

University of Missouri-Columbia
AB, Economics/Mathematics Phi Beta Kappa, Alpha of Missouri
1966-1970
Honors/Awards:

Phi Beta Kappa, Alpha of Missouri, 1969

Meritorious Civilian Service Medal, 2000
Superior Civilian Service Medal, 2001
Superior Civilian Service Medal, 1994
Medallion and Citation from Secretary of the Army, Honorable Luis Caldera, 1999
Commander's Medal for Civilian Service, 1996

References

Mr. Robert K. Dawson

President, Dawson and Associates

4
Former Assistant Secretary of the Army for Civil Works
(202} 289-2060 rdawson@dawsonassociates.com

Dr. G. Edward Dickey

Former Deputy Assistant Secretary of the Army for Civil Works and
and Chief, Planning Division, United States Army Corps of Engineers
(410} 467-9545 gedickey@verizon.net

Mr. Fowler C. West

President, West and West, LLC
Representative, Everglades Trust
Former Member, Commodity Futures Trading Commission
Former Chief of Staff, House Agriculture Committee
(571) 483-5010 fwest@westandwestdc.com

Bob Young,
President, Eagle Veterans Services, LLC
Former Mayor, Augusta Georgia; Former Asst Dpty Sec, HUD:
Former Chair, Mayor's Water Council, US Conference of Mayors
706-825-1011
mayoryoung@comast.net

More information on awards and accomplishments is available at:

https://www.linkedin.com/in/larryprather