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Army Corps 35% design requirement halts Middle Creek validation study and raises engineering costs

Middle Creek Restoration Project Committee · June 1, 2026
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Summary

The committee was told that a new U.S. Army Corps policy requiring 35% design completion paused the validation study, adding LIDAR, geotechnical, hydraulic analyses and other costly tasks that the project currently lacks funding to complete.

Committee members were informed April 6 that the U.S. Army Corps of Engineers (USACE) has paused the Middle Creek validation study after a federal policy change requiring projects to reach 35% design before advancing. County staff and Army Corps representatives said the project had been advancing on assumptions consistent with a 25% design standard; the new requirement increases engineering scope and cost and leaves the existing project funding insufficient to complete the validation work.

Army Corps staff told the committee that meeting the 35% threshold would require additional LiDAR and survey work, a hydraulic basis-of-design analysis, geotechnical investigations with borings and modeling, and more detailed infrastructure design. County participants noted that recent countywide LiDAR and existing GIS data could help reduce some costs and offered to collaborate to identify local resources.

Committee members described the policy shift as a mid-project change that has affected projects nationwide and encouraged coordinated advocacy. The committee agreed to convene a broader coordination meeting among Army Corps staff, county staff, PG&E and Caltrans to clarify the exact documentation and design deliverables needed to reach 35% and to pursue written funding clarification to support local advocacy to Congressman Thompson’s office.

Members expressed frustration at the timing of the federal policy change and emphasized the urgency of identifying funding and technical resources to avoid further delays to the validation study.