Last week Senator Sullivan sent an email to Homer residents trumpeting what he has recently accomplished for Alaska. Part of the email discusses the proposed Homer Harbor Expansion. I think this discussion needs another perspective.

Sullivan’s letter said, “I fought to reform [i.e. exempt] the Port Infrastructure Development Program’s cost-benefit analysis requirements to better account for Alaska’s unique circumstances.” I’m not sure that exempting Alaska projects from fiscal accountability does us any favors. I think it encourages more boondoggles. If anything, Alaska’s harsh conditions need good professional standards that ensure we have qualified contractors who can build quality infrastructure. It’s those who want to bend the rules that we need to watch.

An example where Alaska raised the bar (not lowered it) to “account for Alaska’s unique circumstances” is AHFC’s Building Energy Efficiency established in the 1990s. This program finances home construction if the project can demonstrate a 5-star energy efficiency rating. Initially, building contractors opposed these standards, using arguments much like Sullivan’s. Eventually they saw that quality home construction usually results in lower heating bills. Now, the Alaska State Home Builders Assoc. says, “We are committed to upholding high standards in the building industry.” Before Sullivan went to battle over cost-benefit analysis requirements, he should have held a public meeting to see if Homer supports exempting fiscal accountability.

The manual for the Port Infrastructure Development Program economic analysis lists the following requirements for benefit-cost-analysis:

• For large projects (other than projects located in noncontiguous States and territories), USDOT must determine that the project will be cost-effective in order for it to be selected under the PIDP.
  

• Cost-effectiveness determinations based on the results of the BCA– Projects must be found to have estimated benefits that are likely to exceed costs in order to be deemed cost-effective.
  
• Include all costs of implementing the project– e.g., design, ROW acquisition, construction– Regardless of funding source– Include previously incurred costs.
  
• Benefit-Cost Ratio (Benefits/Costs)– Denominator should only include capital costs (i.e., net maintenance costs and residual value should be in the numerator)– Dis-benefits should be subtracted from the numerator. 
  

So, what is the Benefit-Cost Ratio for Alternative 2, the option selected by the Homer City Council as the Tentatively Selected Plan? According to Appendix C Economics in the Draft Integrated Feasibility Report and Environmental Assessment for the Homer Navigation Improvements Study, AK Alternative 2 had a Benefit-Cost Ratio of 0.77. It should be noted that this calculation is probably optimistic because, for one, the analysis did not include any dis-benefits to biological resources or user groups. 

Also, the Executive Summery says “No alternative plan reasonably maximized NED benefits or resulted in a benefit-cost ratio (BCR) above 1, indicating that a plan could not be selected on the merits of the NED analysis alone … {However}amended Section 1147…. allows the Secretary of the Army to recommend a project without the need to demonstrate that the project is justified solely by NED benefits if the project is located in Alaska and over 80% of the goods transported through the harbor would be consumed within the United States. Homer Harbor meets these requirements.”

This raises the question, are there potential harbor sites in Kachemak Bay that might have an acceptable BCR? I think so. Neither the Corps nor HDR seriously considered any alternative that gives priority to satisfying current needs for recreation and small fishing boats. Their agenda is to build big harbors for large vessels used for industrial purposes, like shipping.

What may be the most affordable harbor expansion is to excavate the fenced-in area near the Harbor Master’s building, flood it, and use this for mooring large vessels. In my 22 years of living in Homer, I haven’t seen much use of this large space. Obviously, recreation boat users don’t need it. This option, besides not needing much new and expensive breakwater construction, seems to have more capacity than the System 5 area now used for mooring large vessels. Also, it has a road on both sides and straighter entrance into the harbor. Moving large vessels to this area would open-up the current System 5 area to small boat moorings, increasing capacity by about a third. And finally, the fill removed could probably be sold, thereby defraying some of the costs of construction.

Perhaps the biggest advantage of the option mentioned above is that it won’t have the biological impact that Alternative 2 will have, which I consider fatal flaws. Briefly:

• The northeastern side of Alternative 2 harbor and access channel is within the Kachemak Bay Critical Habitat Area. Its statutory purpose is to “protect and preserve habitat areas especially crucial to the perpetuation of fish and wildlife, and to restrict all other uses not compatible with the primary purpose.” The Corps has stated, “The alternatives are not compatible with the Kachemak Bay State Critical Habitat Area Management Plan.”
  
• The east shoreline of Homer Spit has significant eelgrass beds, which are highly productive habitat critical to local fish and wildlife. Studies for this project found eelgrass “present within the footprints of all practicable alternatives considered in the study, and there is no practicable alternative that completely avoids it.” Does this comply with CHA law? That wouldn’t be an issue if harbor expansion were within the existing footprint. 
  
• Records show that overwintering sea ducks forage in the area proposed for Alternative 2, including Steller’s Eiders, a Threatened Species. Birds of the World says Steller’s Eiders are “Often associated with marine habitats with sea lettuce, eelgrass, and brown seaweed where small mollusks, gastropods, and crustaceans are abundant.”
  
• The entrance channel proposed for Alternative 2 is right in front of the entrance to the Dudiak Fishing Lagoon, the most popular place on the Homer Spit for king and silver salmon fishing. I and others have questioned whether this dredged channel would divert migrating salmon into the harbor instead of the lagoon, which would have serious impact on Homer Spit sport fishing and the local economy it attracts.

Senator Sullivan’s email also said, “I secured funding to kickstart the Homer Harbor modernization project from the U.S. Army Corps of Engineers to advance and complete the feasibility study. I included a provision in the Water Resources Development Act of 2026 to advance the harbor project to final U.S. Army Corps of Engineers approval and construction.”

I am not sure where Senator Sullivan got the authority to speak for Homer and advance the harbor project to approval. Since Homer area residents will be paying part of the construction costs of this project, the go-ahead should be our decision. Neither the Corps nor HDR or Senator Sullivn should be preempting local decisions or state authority (e.g. CHA). But given that the Corps has not responded to the Draft comments or even made the comments available to the public, it appears as if the public process has fallen apart.

George Matz is a local conservationist whose involvement is mostly with organizing citizen science bird monitoring projects. He also served on the ACOE Homer Harbor Environmental Stakeholder Working Group.