Urban Economics

Corps 404(b)(1) Permit Economic Analysis

Joanne Brion has worked on a number of projects that have required an Army Corps of Engineers 404(b)(1) permit, which is required to fill waters of the U.S., including wetlands, vernal pools, streams, and stream habitat. The use of this federal permit is becoming more common because the number of filled acres triggering a permit is now lower. Part of the process for applying for a 404 permit is preparing what is called an Alternatives Analysis. The Alternatives Analysis is required to determine the Least Environmentally Damaging Practicable Alternative (LEDPA). The burden of determining the LEDPA is on the developer who must consider logistics, technology and cost as factors that can affect project alternatives. Cost is not well defined in the Corps regulations and the analysis cannot consider “profit” per se. While working with EPS, Ms. Brion helped develop a method of analyzing alternatives using the “cost/burden” measure. Cost burden is a planning level tool which provides a reliable measure of the relative financial feasibility of a project. Cost burden considers the financial burden of a project’s required site preparation and infrastructure (i.e., grading, roads, bridges, water, sewer, storm drainage systems and utilities, as well as City and Special District required impact fees). Alternatives are not practical if the cost to develop infrastructure is substantially greater than the project can support. Other screening tools used to evaluate alternatives include market demand, growth projections, project absorption, fiscal impacts, and financial performance, among other things. Ms. Brion has prepared the economic analyses for the Alternatives Analysis for the following projects:

  • Fagan Canyon, Santa Paula
  • Gale Ranch – Dougherty Valley, San Ramon
  • Lagoon Valley, Vacaville
  • Palos Colorados, Moraga
  • Suisun City Marketplace, Suisun City (in progress)
  • Walpert Ridge (now Blue Rock Country Club), Hayward
  • Weber Industrial Property, Hayward



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