From a Small Town Perspective: Owning NRCS

Abstract Only - NRCS (formally SCS) constructed over 11,000 dams throughout the United States starting in 1949 to present day. The majority of these dams were designed as a single-purpose flood control device to protect citizens from flash flooding in areas of large elevation changes and often in rural municipalities.
During the height of the projects, the Federal Government (SCS) would design, construct and provide future engineering tasks for the dams after ownership was transferred to the municipality. This case perspective is from Cattaraugus County where 11 NRCS dams are currently in place and maintained by the County. As owner, the County has been responsible for the maintenance, inspection, safety and day-to-day responsibilities since the transfer of ownership.
The benefits of these dams are plain for those in the familiar with the design and functionality of flood retention dams. However, for the communities that now own the dams, having 11 large-scale dams to maintain can be challenging sell for a small municipality in terms of labor and funding to a community that no longer remembers the floods before the dams were in place. The New York State Department of Environmental Conversation Dam Safety (NYSDEC) regulates the dams. Like most regulatory districts, the NYSDEC requires Engineering Assessments, Emergency Action Plans, inspections and certifications on an annual basis. The original agreement with NRCS had all engineering tasks to be placed under NRCS oversight and to be completed by NRCS New York State staff. However, NRCS has been unable to provide these inspections and reports to NYSDEC as they have been subject to budget constraints. This forces the County to fund the engineering tasks either by County personnel or by hiring a private consultant.
Reclassification of the County owned dams has also been a consideration of NRCS recently. While reclassifying a dam is necessary from time to time due to downstream development, the requirements for hydraulic design vary from NRCS to NYSDEC regulations, with the NYSDEC regulations being less stringent than that of the NRCS. (NYSDEC allows existing high hazard dams to be designed for the ½ PMF, while NRCS dictates the full PMF.) While NRCS may require a classification change to a higher risk category dam under their program, the NYSDEC regulations may not. Furthermore, this change in risk category could require physical changes (Spillway capacity, increased embankment heights, etc.) to the dams under consideration. These required modifications could carry a multi-million-dollar price tag causing a cash-strapped County to be responsible for approximately for 30% of the total construction cost. Due to the difference in design criteria, all of the County-owned dams are currently compliant under NYSDEC guidelines and would not need to be enlarged or modified to stay within compliance
Because of the above-described situation, the county is now faced with the difficult decision of whether to remain in the NRCS program, which will cost potentially millions of dollars for dam improvements, or drop out of the program and take on all regulatory compliance costs on their own. In addition, there is the question of potential risk for designing to lesser state regulations rather than the stricter NRCS guidelines.