oversight

Hydroelectric Dams: Issues Surrounding Columbia River Basin Juvenile Fish Bypasses

Published by the Government Accountability Office on 1990-09-06.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                             United   States    General   Accounting     Office    -_ .. T+


GAO                          Report to the Chairman, SubcomqGttee
                             on Oversight and Investigations,
                             Committee on Energy and Commerce,
                             House of Representatives

September   1990
                             HYDROELECTRIC
                             DAMS
                             Issues Surrounding
                             Columbia River Basin
                             Juvenile Fish Bypasses




                   -__ -,-                 _-                          - __.,,
                                                                           .- ,_


                       REsTRIcrED    --Not   to be released outside the
                       General Accounting Of&e unless spedilcally
                       appruved by the OfYlce of Congressional
                       Belatlona


GAO,‘RCED-90-180
Resources, Community,   and
Economic Development    Division

B-225290.7

September 6, 1990

The Honorable John D. Dingell
Chairman, Subcommittee on
  Oversight and Investigations
Committee on Energy
  and Commerce
House of Representatives

Dear Mr. Chairman:

In accordance with your request, this report provides our evaluation of the controversy
surrounding the Corps of Engineers program for assisting fish migration past certain
Columbia and Snake River dams.

As arranged with your office, unless you publicly announce its contents earlier, we plan no
further distribution of this report until 30 days from the date of this letter. At that time we
will provide copies of the report to the Secretary of Energy; the Administrator, Bonneville
Power Administration; the Chairman, Northwest Power Planning Council; the Secretary of
Defense; the Director, Office of Management and Budget; and other relevant agencies. We
will also make copies available to other interested parties upon request.

This work was done under the direction of Victor S. Rezendes, Director, Energy Issues, who
can be reached at (202) 275-1441. Other major contributors are listed in appendix II.

Sincerely yours,




Y
J. Dexter Peach
Assistant Comptroller General
Executive Summq                                                                                  .


                   Hydropower facilities in the Columbia River Basin have contributed to
Purpose            an estimated 80 percent decline in the numbers of salmon and steelhead
                   trout that migrate to the ocean as young fish and return as adults to
                   spawn. While undertaking numerous efforts to assist fish migration
                   around its dams, the U.S. Army Corps of Engineers decided against con-
                   structing bypasses at two dams to help young fish migrate to the ocean
                   because it concluded that the bypasses’ economic benefits would not
                   outweigh their costs, However, fish and wildlife agencies, Indian tribes,
                   and others contend that the Corps’ decision rests on a flawed analysis.

                   The Chairman, Subcommittee on Oversight and Investigations, House
                   Committee on Energy and Commerce, asked GAO to examine the Corps’
                   (1) use of benefit and cost analysis and a computer model used to esti-
                   mate benefits, (2) consideration of other factors in its benefit estimates,
                   and (3) consideration of the views of outside groups in deciding against
                   constructing the bypasses. In addition, GAO agreed to provide informa-
                   tion about bypass effects on fish survival.


                   Since 1933, the Corps and others have constructed 18 major dams on the
Background         Columbia and Snake Rivers to generate electric power, irrigate farm
                   lands, provide flood control, and extend barge traffic. While providing
                   benefits, the dams have also reduced the annual fish migrations that are
                   commercially and socially important to the region and have cultural,
                   religious, and economic significance to Indian tribes.

                   Because of their critical locations on the lower Columbia and Snake
                   Rivers, eight Corps dams represent barriers to a large number of migra-
                   tory fish. Although the percentage of declining fish migrations attribu-
                   table to all its dams has not been determined, the Corps, among other
                   actions to offset the impact of the dams, has constructed bypasses at
                   five of the eight critical dams. The bypasses divert young fish migrating
                   downstream away from electricity-generating turbines, where they can
                   be killed or stunned and made easy targets for predators. In 1988 and
                    1989, the Corps concluded that the cost of building bypasses was justi-
                   fied at only one of the three remaining dams and requested no funds to
                   construct bypasses at The Dalles and Ice Harbor Dams. However, in
                    fiscal years 1988-90, the Congress appropriated money for designing
                   bypasses at the two dams, and the Corps is currently designing them.


                   In estimating benefits, the Corps relied heavily on the results generated
Results in Brief   by a computer model, despite the model’s known limitations, and it


                   Page 2                          GAO/IWED~l80    Columbia   River Basin Fish Bypawea
                          Executive   Summary




                          excluded from consideration several potential benefits that would have
                          resulted in the bypasses’ estimated benefits exceeding their estimated
                          costs. For example, the Corps did not recognize the potential electricity
                          revenues currently foregone by using water to “spill” young fish
                          through dams rather than to generate electricity. In addition, the Corps
                          did not consider some potential noneconomic benefits, such as the fishes’
                          cultural and religious value, although its engineering regulations require
                          that noneconomic benefits be taken into account. Also, the Corps did not
                          adequately involve fish and wildlife agencies, tribes, or others, as its
                          engineering regulations require, in the studies that led to its decision,
                          and did not revise its conclusion after the groups raised valid concerns
                          when the decision was announced.

                          The bypass controversy is indicative of an underlying issue: the Corps is
                          not obligated to restore the numbers of migrating fish to a specific level
                          and therefore has no benchmark to assess the need for additional fish
                          migration projects. Decisions about the proposed bypasses are further
                          hampered by the scarcity of information about bypass effectiveness in
                          enhancing the survival of migrating juvenile fish.



Principal Findings

Problems With Benefit     To estimate the number of additional adult fish that would return from
                          the ocean if the proposed bypasses were constructed, the Corps used a
Analysis and Inadequate   computer model it developed called FISHPASS. The model simulated the
Regional Involvement      likely survival of young fish passing the eight critical dams on their way
                          to the Pacific Ocean, both with and without the proposed additional
                          bypass facilities at the three dams. By applying a dollar value to the
                          number of returning adults, the model calculated the economic benefits
                          of the returning fish. However, local agencies, tribes, and others noted
                          many limitations in the model, and a review by University of Wash-
                          ington researchers concluded that data limitations render FISHPASS inade-
                          quate for making precise determinations of economic benefits. The
                          Corps has acknowledged shortcomings in the data used in the model and
                          the resultant effects on the model’s reliability.

                          By changing certain underlying assumptions used to estimate the bene-
                          fits, the Corps’ analysis could have reached the opposite conclusion. For
                          example, the Corps did not recognize the potential electricity revenues
                          currently foregone by using water to “spill” young fish through the two


                          Page 3                         GAO/RCED-9@180   Columbia   River Basin Fish Bypasses
                             Executive   Summary




                             dams rather than to generate electricity. Bypasses would enable using
                             spilled water for electricity generation, thus causing the bypasses’ esti-
                             mated benefits to exceed estimated costs at both dams. Similarly, the
                             Corps did not consider some potential benefits, such as the cultural and
                             religious value of fish to the Indian tribes, although its regulations
                             require that such noneconomic factors be considered.

                             Although Corps regulations require it to conduct planning studies in an
                             open atmosphere to obtain public understanding, trust, and cooperation,
                             the Corps did not adequately involve the agencies, Indian tribes, or
                             other groups in preparing reports on which it based its conclusions
                             about the costs and benefits of the two bypasses. Corps officials said
                             that the reports either were considered to be internal documents or were
                             prepared outside the usual planning process. However, because the
                             studies were used to help make bypass decisions, GAO believes that the
                             Corps should have involved groups with an interest in the bypasses.


No Specific Mitigation       The Corps has no legal obligation to restore the numbers of salmon and
                             steelhead trout on the Columbia and Snake Rivers to a specific level.
Objective and Insufficient   Establishing a specific mitigation objective would enable the Corps to
Information on Bypass        base decisions about proposed projects on their contribution to
Effectiveness                achieving the objective, including projects like the disputed bypasses
                             that were previously rejected on a strict economic cost/benefit basis.
                             This would help the Corps and the Congress decide how to assist down-
                             stream fish migration in the most cost-effective manner. However,
                             establishing a mitigation objective may be difficult because, according to
                             Corps officials, comprehensive data on fish migrations prior to construc-
                             tion of the dams do not exist.

                              The ability to base bypass construction decisions on cost effectiveness
                              may be limited because information about bypass effectiveness is scarce
                              and inconclusive. Although many studies of existing bypasses have been
                              conducted, they have focused on the numbers of juvenile fish entering
                              the bypasses and the fishes’ condition after passage. Officials of the U.S.
                              Fish and Wildlife Service, the National Marine Fisheries Service, and the
                              Corps could identify only two studies that, at the same dam, compared
                              bypasses with alternative ways of getting past the dam. While the
                              results are preliminary, the studies raise questions about the studied
                              bypasses’ effectiveness. For example, an ongoing Fisheries Service study
                              shows a higher survival rate for young fish passing through hydroelec-
                              tric turbines than through a bypass.



                              Page 4                         GAO/RCED4@1f30   Columbia   River Basin Fish Bypaasea
                      Executive   Summary




                           recommends that the Secretary of the Army direct the Chief, Corps
Recommendations       GAO
                      of Engineers, in consultation with fish and wildlife agencies, Indian
                      tribes, and other interested groups, to establish a mitigation objective
                      and determine which measures, such as bypass facilities, are necessary
                      to meet that objective. GAO also makes several recommendations for
                      improving future analyses of the benefits of projects designed to
                      enhance the survival of migrating fish.


                      Since no specific Corps mitigation objective exists and recent studies
Options for           have raised questions about bypass effectiveness for increasing the
Congressional         number of migrating fish, the Congress appears to have three main
Consideration         options for bypass facilities at Lower Monumental, The Dalles, and Ice
                      Harbor Dams. They are to direct the Corps

                  l to proceed with planning or constructing the bypasses as currently
                    authorized, without establishing a specific mitigation objective or fur-
                    ther studying bypass effectiveness;
                  l not to proceed with planning or constructing the bypasses until the
                    Corps has established a mitigation objective and determined that the
                    bypasses are cost effective; or
                  . to postpone construction of the bypasses until completion of both the
                    mitigation study and additional research on the effectiveness of
                    bypasses in comparison to other alternatives that affect juvenile fish
                    passage and survival.


Agency Comments       Corps, the Bonneville Power Administration, the Pacific Northwest
                      Power Planning Council, fish and wildlife organizations, a local utility
                      group, and the Office of Management and Budget. The officials generally
                      concurred with the factual information. As requested, however, GAO did
                      not obtain official comments on this report.




                       Page 5                        GAO/RCED-So-180   Columbia   River Basin Fish Bypasses
Contents


Executive Summary                                                                                                  2

Chapter 1                                                                                                          8
Introduction                    Dams Impede Fish Migration                                                        10
                                Efforts to Improve Downstream Migration                                           10
                                Regional Plans Call for Increasing Fish Runs                                      12
                                The Corps Decided Against Bypasses at Two Dams                                    13
                                Objectives, Scope, and Methodology                                                14

Chapter 2                                                                                                         16
Limitations in Benefit Results Generated by FISHPASS Model Were Used                                              16
                           Inappropriately
Analysis and Regional Results  of Benefit and Cost Analysis Are Sensitive to                                      19
Involvement Raise          Discretionary Assumptions
                       The Corps
Questions About Corps Conclusions Gave Limited Consideration to Others’ Views                                    23
                                                                                                                 27
Bypass Decisions       Recommendations                                                                           27

Chapter 3                                                                                                         29
Fish Bypass Decision- While Difficult to Establish, Mitigation Objective Would                                    29
                            Provide Benefits
Making Is Hampered Bypasses’      Effect on Juvenile Fish Survival Is Inconclusive                               31
by Lack of Specific    Conclusions                                                                               33
Objectives and Data on Recommendations
                       Options for Consideration by the Congress
                                                                                                                 33
                                                                                                                 34
Bypass Effectiveness
Appendixes                      Appendix I: Consolidation of Fish and Wildlife Agencies’,                         36
                                    Indian Tribes’, and the Council’s Concerns; Corps’
                                    Responses; And GAO’s Observations
                                Appendix II: Major Contributors to This Report                                    54

Tables                          Table 1.1: Groups and Agencies With Responsibilities for                          12
                                    Columbia River Fish
                                Table 2.1: Corps’ Estimated Costs and Benefits of                                 17
                                    Proposed Bypass Facilities
                                Table 2.2: Comparison of Proposed Bypass Projects With                            20
                                    and Without Benefit of Avoided Spill




                                Page 6                        GAO/RCED!30-160   Columbia   River Basin Fish Bypasses
          Contents




Figures   Figure 1.1: Columbia and Snake River Dams on Fish
               Migration Route
          Figure 1.2: System for Diverting Juvenile Fish Away                            11
               From Turbines




          Abbreviations

          BPA        Bonneville Power Administration
           FWS       U.S. Fish and Wildlife Service
          GAO        U.S. General Accounting Office
          OMB        Office of Management and Budget


           Page 7                       GAO/RCED-W18O   Columbia   River Basin Fish Bypasses
Introduction


                   Since the 193Os, hydropower development and operations in the
                   Columbia River Basin have caused the number of migrating adult fish to
                   decline by an estimated 60 percent. These anadromous fish, particularly
                   salmon and steelhead trout, hatch in fresh water, migrate to the sea, and
                   return to their hatching ground where most lay eggs and die. During
                   their downstream migration, an estimated 10 percent to 30 percent of
                   the juvenile fish may be killed as they pass through power-producing
                   turbines at each dam. To avoid the passage of juvenile fish through the
                   turbines, the U.S. Army Corps of Engineers (Corps) and other dam oper-
                   ators have spent millions on structural bypass systems and other
                   improvements at some dams.


                   The Columbia River Basin encompasses parts of several northwestern
Dams Impede Fish   states and southwestern Canada. Since 1933, 18 major dams have been
Migration          built on the Columbia River and its main tributary, the Snake River, by
                   the Corps, the Department of the Interior’s Bureau of Reclamation, or
                   public utility districts. These dams have hydroelectric facilities that pro-
                   duce a significant amount of the region’s electricity, some have naviga-
                   tion locks that extend barge transportation up the rivers, and some have
                   reservoirs that are used for flood control and irrigation.

                   While providing many benefits, the Columbia River dams present bar-
                   riers to migrating fish. This is particularly important for eight Corps
                   dams, which because of their critical location on the lower Columbia and
                   Snake Rivers represent barriers to the greatest number of fish, as shown
                   in figure 1.1. Each stream or other tributary in the basin is a potential
                   home for a specific fish “stock,” a species or subspecies affiliated with a
                   particular spawning ground. The annual return of adult salmon and
                   steelhead trout, referred to as “fish runs,” is of significant economic and
                   social importance to the region and of economic, religious, and cultural
                   importance to local Indian tribes.’ The average annual run is now an
                   estimated 2.5 million fish.




                   ‘Total fiih runs include adult fiih that are harvested in the ocean or in the Columbia River before
                   reaching any dams.



                   Page 8                                     GAO/ECEMO-180       Columbia   River Basin Fish Bypa.sms
                                       Chapter 1
                                       Introduction




Figure 1.1: Columbia and Snake River
Dams on Fish Migration Route




                                                            1. Bonneville               5. Ice Harbor
                                                            2. The Dalles               6. Lower Monumental
                                                            3. John Day                 7. Little Goose
                                                            4. McNaty                   8. Lower Granite



                                                      lsl   Fishcsnnot migrate psst damsat thsss points.




                                       To increase the number of adult fish migrating upstream, facilities such
                                       as fish ladders were built to allow the fish to pass upstream.’ However,
                                       the dams also impede the downstream migration of juvenile fish, which
                                       in turn can affect the number of returning adults. Initially, most dams
                                       were constructed with two primary ways for juvenile salmon and steel-
                                       head trout traveling downstream to get past: (1) in spillage, or water
                                       purposely spilled over the dam, and (2) through the turbines of hydroe-
                                       lectric generators.3 It was found that the turbines killed 10 to 30 percent
                                       of the juveniles at each dam and stunned, injured, or disoriented others,
                                       making them easy targets for predators.

                                       ‘No ladders were built at the Chief Joseph, Grand Coulee, or Hells Canyon Dams; consequently, fish
                                       migration above these dams is no longer possible on the Columbia and Snake Rivers.

                                       “Some dams were constructed with special passages called “sluiceways” to allow ice and river debris
                                       to move past the dam; these provided a third route for downstream migration.



                                       Page 9                                     GAO/RCEMO-190        Columbia   River Basin Pish Bypasses
                     Chapter        1
                     Introduction




                     Although the decline in fish runs coincides with the construction and
                     operation of the hydropower dams, the decline is attributable in part to
                     other causes. These include irrigation and flood control measures;
                     overfishing; poor logging, grazing, and farming practices which add to
                     erosion and devegetation of shoreline habitat; and siltation of spawning
                     beds. The total decline from all causes is estimated to be about 80
                     percent.


                     The Corps and public utility districts have spent millions of dollars on
Efforts to Improve   structural bypasses and other improvements at some dams to avoid pas-
Downstream           sage of juvenile fish through turbines. These bypasses are designed to
Migration            divert the juvenile fish away from the turbines and into special conduits
                     that allow them to reenter the river below the dam. In some cases, the
                     conduits are used to collect the fish for loading into trucks or onto spe-
                     cial barges, which then proceed downriver and discharge the fish at a
                     point below Bonneville Dam. Bonneville is the last dam before the river
                     enters the sea.

                     Five of the eight Corps dams on the lower Columbia and Snake Rivers
                     have “traveling-screen” bypass systems, built between 1976 and 1982.
                     Essentially, the screens are rotating devices submerged near the intake
                     openings leading to the turbines; they are used to guide at each dam 19
                     to 86 percent of juvenile fish (depending on species) away from the
                     intakes toward a special passage conduit (see fig. 1.2). Traveling-screen
                     bypasses have not been built at the other three Corps dams: The Dalles,
                     Ice Harbor, and Lower Monumental. The Dalles and Ice Harbor Dams
                     have ice and trash sluiceways which can be used to divert an estimated
                     13 to 58 percent of the juvenile fish around the turbines and back into
                     the river below the dams. At Lower Monumental, the primary alterna-
                     tive to passing through the turbines is spillage, but construction of a
                     traveling-screen bypass is scheduled for completion in 1992.




                     Page IO                        GAO/RCED-!l@ltMl   Columbia   River Basin Fish Bypasses
                                           Chapter 1
                                           Introduction




Figure 1.2: System for Diverting Juvenile Fish Awav From Turbines




                                                                                                LEGEND
                                                                                              @ Navigation Lock-Barge
                                                                                              - Passage Around Dam
                                                                                              @ Spillway-Passage
                                                                                                 through Dam.
                                                                                              @ Sluiceway-Debris and Ice
                                                                                                 Passage through Dam
                                                                                              @ Powerhouse-Passage
                                                                                                 through Turbine Blades
                                                                                              @ Submerged Traveling
                                                                                                 Screens- Bypass Facility




                                            The Corps has also constructed eight hatcheries to compensate for losses
                                            caused by the four Corps dams on the Snake River, and another
                                            hatchery is scheduled for completion by 1991. To compensate for losses
                                            caused by the John Day Dam on the Columbia River, two hatcheries
                                            were enlarged.




                                            Page 11                       GAO/RCED-90-180   Columbia   River Basin Fish B> passes
                                                    chapter 1
                                                    Introduction




                                                    In 1980 the Congress passed legislation creating the Northwest Power
Regional Plans Call for                             Planning Council and directing it to plan, among other things, for
Increasing Fish Runs                                enhancing and protecting fish and wildlife affected by the Columbia
                                                    River dams. The Council, an interstate agency, is required to consult
                                                    with a variety of groups in carrying out its responsibilities. The groups
                                                    and agencies primarily involved in developing the Council’s fish pro-
                                                    gram and their responsibilities are shown in table 1.1.

                                                    As an interim goal, the Council’s program calls for approximately doub-
                                                    ling the existing annual adult fish migration on a sustainable basis, from
                                                    2.5 million to 5 million. To help achieve this goal, the program calls for
                                                    constructing traveling-screen bypasses at Corps dams where such
                                                    screens do not exist and improving existing bypasses. The program does
                                                    not specify a time frame for achieving the goal or constructing the
                                                    bypasses. In 1984 and 1987, the Council program recommended that the
                                                    Corps install traveling-screen bypasses at The Dalles, Ice Harbor, and
                                                    Lower Monumental Dams.


Table 1.1: Grouts and Aaencies With Resoonsibilities               for Columbia River Fish
Groups and agencies                                                           Responsibilities
Bonneville Power Administration,    Department of Energy                       Marketing electricity from Columbia Basin federal hydroelectnc
                                                                               dams; protecting, mitigating, and enhancing fish and wildlife
                                                                               consistent with the Council’s program
Columbia Basin Fish and Wildlife Authority                                     Representing federal and state fish and wildlife agencies and Indian
                                                                               tribes before the Council, Bonneville, and the Corps
Columbia River Intertribal Fish Commission                                     Providing technical and biological fisheries services to the Nez Perce,
                                                                               Umatilla, and Warm Spring tribes and the Yakima Nation
Federal Energy Regulatory Commission, Department of Energy                     Approvtng and licensrng nonfederal hydroelectric projects, taking
                                                                               into account the Council’s fish and wildlife program
Fish and wildlife   agencies in the states of Idaho, Montana, Oregon,          Managing fish resources, including operating hatcheries (all except
and Washington;      National Marine Fisheries Service, Department of          National Marine Fisheries) and conducting research
Commerce; and       the U.S. Fish and Wildlife Service, Department of the
Interior
Indian tribes-13     tribes In the Columbia Basin                              Managing fish and wildlife, constructing and operating hatcheries,
                                                                               conducting research, and improving habitat
Northwest Power Planning Council                                               Policy-making and planning for electrical power and the Columbia
                                                                               River Basin’s fish and wildlife; charged with developrng and adophng
                                                                               a proaram to “protect, mitiaate, and enhance fish and wildlife”
Pacific Northwest Utilities Conference Committee                               Representing Pacific Northwest utilities in regional planning
Private and publicly owned utilities                                           Building and operating dams and hydroelectric facilities
State water management agencies in Idaho, Montana, Oregon, and                 Regulating water resources
Washington
U.S. Corps of Engineers, Department of the Army; and the Bureau of             Building and operating federal dams, taking into account the
Reclamation, Department of the Interior                                        Council’s program for protecting, mitigating, and enhancrng fish and
                                                                               wildlife to the fullest extent oractical




                                                     Page 12                                     GAO/RCED-90-180   Columbia   River Basin Fish Bypasses
                      Chapter 1
                      Introduction




                      According to Corp officials, the Corps is responsible under federal law
The Corps Decided     for identifying adverse effects caused by its dams. However, it is not
Against Bypasses at   specifically required to mitigate this damage on completed projects or to
Two Dams              follow the Council’s plans. To assess whether the Council’s recommen-
                      dation should be followed, the Corps conducted benefit and cost studies
                      for the recommended bypass facilities at the three dams and for other
                      proposed bypass improvements. On the basis of analyses reported in
                      1988 and 1989, the Corps concluded that, regardless of the impact on
                      attaining the Council’s goal, the costs of bypass facilities at The Dalles
                      and Ice Harbor Dams would exceed their benefits. Therefore, according
                      to a Corps headquarters official, the Corps did not seek funds to con-
                      struct the two bypasses.

                      Two 1988 reports-one prepared by the Corps’ North Pacific Division,
                      (Division) which is responsible for the Columbia River Basin area, and
                      one prepared by a team from Army and Corps headquarters-concluded
                      that traveling-screen bypasses should be constructed at Lower Monu-
                      mental Dam, but not at Ice Harbor and The Dalles Dams. The Corps
                      sought funding for the bypass at Lower Monumental Dam. A March
                      1989 report, prepared by the Division’s Portland (Oregon) District,
                      found that the estimated benefits did not exceed the estimated costs of
                      constructing submerged traveling screens at The Dalles Dam, and did
                      not recommend that the screens be constructed.

                      Following the Corps’ reports, the Northwest Power Planning Council,
                      Indian tribes, and fish and wildlife agencies questioned many aspects of
                      the methodology and procedures leading to the Corps’ conclusions. Gen-
                      erally, the groups believed that the Corps’ analyses understated the
                      effective benefits of constructing traveling-screen bypasses. Their con-
                      cerns included questions about (1) the validity of FISHPASS, the computer
                      model the Corps used to calculate the number of returning adult fish; (2)
                      the Corps’ decision not to consider as a bypass benefit the additional
                      revenue possible from using water currently used to spill fish over the
                      dams to generate electricity instead; and (3) the Corps’ decision not to
                      consider noneconomic benefits, such as the cultural and religious value
                      of the fish to the Indian tribes, in the analysis. These groups have con-
                      tinued to advocate construction of traveling-screen bypasses at The
                      Dalles and Ice Harbor Dams.

                       Corps officials at the Division said that, even though the Corps has not
                       recommended the The Dalles and Ice Harbor Dam bypasses for construc-
                       tion funding, the decision is not final. A Corps headquarters official
                       stated that the Corps’ proposed budgets for fiscal years 1988-90 did not


                       Page 13                       GAO/RCED-90180   Columbia   River Basin Fish Bypasses
                            Chapter 1
                            Introduction




                            request funds for traveling screen bypasses at the two dams. The Corps’
                            budget proposal for fiscal year 1991 did not include funds for bypasses
                            at the two dams. However, planning work for these bypasses has con-
                            tinued by congressional direction; each year, the Congress has appropri-
                            ated money for and directed the Corps to continue planning the
                            bypasses. For fiscal year 199 1, the Senate and House energy and water
                            appropriations bills provide $2.7 million for continuing bypass work at
                            the two dams.


                            The Chairman, Subcommittee on Oversight and Investigations, House
Objectives, Scope,and       Committee on Energy and Commerce, asked us to examine a number of
Methodology                 issues related to the Corps’ decision not to construct bypasses at The
                            Dalles and Ice Harbor Dams. Specifically, we were asked to examine the
                            Corps’

                        l use of benefit and cost analysis and a computer model used to estimate
                          benefits,
                        . consideration of other factors in its benefit estimates, and
                        . consideration of the views of outside groups in deciding against con-
                          structing the bypasses.

                            In addition, we agreed to provide information about bypass effects on
                            fish survival.

                            We conducted the majority of our work at the Corps’ Division in Port-
                            land, Oregon. We also conducted work at Corps headquarters in Wash-
                            ington, D.C., and the Division’s district offices in Portland, Oregon, and
                            Walla Walla, Washington. We reviewed pertinent Corps reports, studies,
                            and correspondence on the proposed juvenile fish bypass program for
                            the lower Snake and Columbia River dams. In addition, we reviewed
                            laws and Corps engineering regulations applicable to mitigation projects.
                            We visited five of the eight Columbia and Snake River dams where fish
                            bypasses have been installed or are being considered.

                            To answer the first two objectives, our work took several forms. We
                            reviewed Corps engineering regulations and held discussions with Corps
                            officials and representatives of the Council, fish and wildlife agencies,
                            Indian tribes, and other interested groups. We reviewed the Corps’
                            authority for performing a benefit and cost analysis and conducted a
                            detailed review of the analysis. In our examination of the Corps’ use of
                            the FISHPASS computer model, we reviewed the model’s user guide, model
                            documentation, and Corps reports that used the modeling results. At our


                            Page 14                        GAO/RCED-9@180   Columbia   River Basin Fish Bypasses
Chapter 1
Introduction




request, the Corps ran the model assuming that the cost of spill would
be included in the benefit and cost calculation and provided us with the
results. We also discussed the model with researchers at the Center for
Quantitative Science, University of Washington, who are familiar with
FISHPASS.~We did not assess the model ourselves to verify its accuracy,
reliability, or validity. In our assessment of the potential for the Corps’
use of intangible factors, we were assisted by an economist at Wash-
ington State University, Pullman, Washington.

To examine the extent to which the Corps considered the views of the
Council, fish and wildlife agencies, Indian tribes, and other interest
groups, we held discussions with, and obtained documentation from, the
Council; U.S. Fish and Wildlife Service, Department of the Interior;
National Marine Fisheries Service, Department of Commerce; Bonneville
Power Administration (BPA); Pacific Northwest Utilities Conference
Committee; Columbia Basin Fish and Wildlife Authority; and Columbia
River Intertribal Fish Commission. We also consulted the Oregon Depart-
ment of Fish and Wildlife and contacted the Fish Passage Center of the
Columbia Basin Fish and Wildlife Authority regarding the status of the
fish runs.

We reviewed the written concerns on the Corps’ decision not to con-
struct the submerged traveling-screen bypasses that these groups sent
to the Corps and the Subcommittee Chairman. We identified, in total, 30
specific concerns, which are presented in appendix I. The concerns
ranged from assumptions about fish survival in reservoirs, turbines, and
sluiceways to the value assigned to harvestable fish.

We discussed the factual information in this report with officials from
the Corps, BPA, Office of Management and Budget, federal fish and wild-
life agencies, the Council, the Columbia Basin Fish and Wildlife
Authority, and the Columbia River Intertribal Fish Commission, The
officials generally concurred with the factual information. As requested,
we did not obtain official agency comments on a draft of this report. Our
work was conducted between May 1989 and March 1990 in accordance
with generally accepted government auditing standards.




 %onneville Power Administration has contracted with the University of Washington for a review of
 the FISHPASS model it used in assessing the impacts of increased power generation on salmon and
 steelhead.



 Page 15                                 GAO/RCEJMO-180      Columbia   River Basin Fish Bypasses
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Involvement RaiseQuestionsAbout Corps
Bypass Decisions
                       The Corps’ benefit and cost analysis was not a sufficient basis for its
                       decision against constructing traveling-screen fish bypasses at The
                       Dalles and Ice Harbor Dams. In estimating benefits, the Corps inappro-
                       priately ascribed too great a degree of accuracy to the results generated
                       by FISHPASS,which is inadequate to precisely predict the benefits of
                       bypasses. Further, the benefits of building the bypasses would have
                       exceeded the costs if the Corps had included certain additional factors in
                       the analysis, such as the cost of water currently spilled at the dams to
                       assist fish migration.

                       Although Corps engineering regulations require it to conduct planning
                       studies in an open atmosphere to obtain public understanding, trust, and
                       cooperation, it did not invite regional fish and wildlife agencies, Indian
                       tribes, or others to participate in its studies of the proposed bypasses,
                       According to Corps officials, these studies were outside its normal plan-
                       ning process and the public involvement normally required was not
                       needed. However, because the studies were used to help make a decision
                       about the bypasses, we believe that the Corps should have involved the
                       groups with an interest in the bypasses.


                       The Corps inappropriately relied on the benefits calculated by FISHPASS
Results Generated by   as a precise measure on which to base a recommendation to fund con-
FISHPASSModel Were     struction. The Corps, other agencies, and regional groups were aware
Used Inappropriately   that, due to uncertainties and limitations in the assumptions and data
                       FISHPASSrequires to compute benefits, the estimated benefits could not
                       be interpreted as exact amounts. However, in 1988 and 1989 the Corps
                       used FISHPASSresults in that way to justify a decision against recom-
                       mending federal funding for planning or constructing traveling-screen
                       bypasses at The Dalles and Ice Harbor Dams.


FISHPASSDetermined     The Corps used FISHPASSto simulate the likely survival of juvenile
Bypass Benefits        salmon and steelhead passing the eight dams on the lower Columbia and
                       Snake Rivers on their way to the Pacific Ocean, both with and without
                       the proposed additional traveling-screen bypasses at the three dams. In
                       this way, the Corps estimated the numbers of additional (1) juvenile fish
                       that would survive to below Bonneville Dam and (2) adult fish that
                       would return from the ocean, if the proposed bypasses were con-
                       structed. The Corps determined a benefit value by applying an average
                       dollar value to the estimated number of returning fish that would be
                       caught by commercial and sport fishermen. The Corps then compared
                       these benefits with estimated costs to build and operate the bypasses.


                       Page 16                        GAO/RCEIMMS180   Columbia   River Basin Fish Bypasses
                                         Chapter 2
                                         Limitations   in Benefit Analysis and Regional
                                         Involvement     Raise Questions About Corps
                                         Bypass Decisions




                                         As shown in table 2.1, the Corps’ 1988 analysis concluded that under
                                         the best conditions, constructing the traveling-screen bypasses would
                                         result in average yearly benefits that exceeded costs by $586,000 at
                                         Lower Monumental Dam, and average yearly benefits that were about
                                         $1.8 million less than average yearly costs at The Dalles and $870,000
                                         less at Ice Harbor.

Table 2.1: Corps’ Estimated Costs and
Benefits of Proposed Bypass Facilities   Thousands of dollars
                                                                                                      cost          Benefit      Difference
                                         Lower Monumental                                            $1,587           $2,173             $586
                                         The Dalles                                                   5,905            4,045           (1.860)
                                         Ice Harbor                                                   1,976            1,106             1870)


                                         A 1989 analysis of bypass facilities at The Dalles Dam estimated
                                         average yearly costs of $5,856,000 and average yearly benefits of
                                         $5,610,000. The increase in estimated benefits, compared with the 1988
                                         analysis, resulted from changes in some of the data assumptions, such
                                         as the water flows, the number of juvenile fish in the system, and the
                                         number of returning adults.


Although Useful for Some                 University of Washington researchers evaluating FISHPAS~concluded in
                                         March 1990 that the model may be useful in identifying information
Purposes, FISHPASS’                      gaps or making gross comparisons among alternative proposals, but it is
Precision Is Limited                     inadequate to precisely predict the actual benefits of alternative fish
                                         bypass actions. In addition, the Council, fish and wildlife agencies, and
                                         Indian tribes raised numerous concerns about the data and the model
                                         (see app. I.) The Corps also has acknowledged shortcomings in the data
                                         used to develop FISHPASSestimates and the resultant effects on the
                                         model’s reliability.

                                         Prior to the Corps’ benefit and cost analysis, BPA used a version of the
                                         model in 1988 to study the effects that changes in power generation
                                         would have on fish in the Columbia and Snake Rivers.’ Because of con-
                                         troversies that emerged about the model and a recommendation we


                                         ‘BPA’s version of FISHPASSdiffered from the Corps’ in several important respects. For example, it
                                         included only the downstream passage part of the model, while the Corps’ version also mcluded the
                                         number of returning adults and an economic component for benefit and cost analysis. Also, BPA’s
                                         version included different stocks of salmon and steelhead, while the Corps’ included only sprmg chi-
                                         nook, fall chinook, and steelhead. Nonetheless, the two versions are similar enough that the concerns
                                         raised by the review apply to both.



                                         Page 17                                    GAO/RCRD-ml80       Columbia   River Basin Fish   Bypasses
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made in an earlier report for an independent review of FISHPASS,~ BPA
hired researchers at the University of Washington in 1989 to review its
version of the model and the version used by the Corps. One purpose of
the review was to “validate” the model-that      is, to assess whether
users could interpret the results with certainty. The researchers con-
cluded that the Corps’ version of FISHPASS has limitations that preclude
being able to validate it.

The researchers’ March 1990 draft report states that FISHPASS’ accuracy
for predicting downstream survivals cannot be validated because of an
overall lack of biological data. This includes a lack of data on the
number of juveniles being guided into the submerged traveling-screen
bypasses and the survival of juveniles going through the turbines.
According to the draft report, research has been done at only a few
dams with one group of salmon, which requires extrapolating limited
data into major, but questionable, assumptions about important aspects
of fish survival. The researchers have noted that the model may be
useful in identifying information gaps or making gross comparisons of
proposed alternatives, since it would affect all alternatives in the same
manner. However, the draft report states that the lack of data weakens
the model as a predictive tool and therefore makes predictions
problematical.

Several of the local fish and wildlife agencies and Indian tribes pointed
out additional limitations of the model (see app. I). They advised the
Corps of their concern that FISHPASS uses specific numerical values for
assumptions that have a large range. For example, turbine mortality at a
dam may vary from 10 to 30 percent depending on various conditions.
However, FISHPASS cannot use the 10 to 30 percent range; it requires a
single numeric value, such as 20 percent. Consequently, given the large
uncertainty associated with the output results, they said the model
should not be relied on to predict fishery benefits. They also pointed out
that a more appropriate use of the FISHPASS model may be to rank
various fish bypass alternatives for increasing passage of fish
downstream.

In 1988 the Army conducted a review of the Corps’ fish bypass program
at the request of the Office of Management and Budget and noted that
“the level of uncertainty attached to estimates of adult returns is unac-
ceptable.” The Division acknowledged that the results are subject to

 %xt&     Power: Issues Concerning Expansion of the Pacific NorthwestSouthwest Intertie (GAO/
        88-199, Sept. 1988).



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                           chapter 2
                           Limltatlons in Benef¶t Analysis and Regional
                           Involvement   Raise Questions About Corps
                           Bypass Decisions




                           question because of uncertainties concerning data used in the model.
                           The Corps agreed that the model uses single numerical values and did
                           not consider probability distributions to estimate the expected error
                           range of the model’s outputs. The Army report indicated that while the
                           actual degree of uncertainty in the model is not measurable, it must be
                           assumed to be broad.


                           The Corps’ estimates showed that the costs of traveling-screen bypasses
Results of Benefit and     at The Dalles and Ice Harbor would exceed their benefits. However, the
Cost Analysis Are          estimated benefits could have exceeded the estimated costs by changing
Sensitive to               certain discretionary underlying assumptions that would have increased
                           estimated benefits.3 Specifically, the Corps did not consider (1) the ben-
Discretionary              efit of using water, currently spilled to assist fish migration, instead to
Assumptions                generate electricity, (2) potential differences in the economic value of
                           fish stocks, and (3) the noneconomic value of fish.


Benefit of Avoided Spill   The estimated benefits of traveling-screen bypasses at The Dalles and
                           Ice Harbor would have exceeded the estimated costs if the Corps had
                           included the value of water currently used to spill migrating fish over
                           the dam, as noted by the Council, regional fish and wildlife agencies, and
                           Indian tribes. Construction of traveling-screen bypasses, if effective,
                           may make it possible to increase fish runs without spillage. This would
                           enable the spillage to be avoided in the future, and make the water
                           available to produce power.

                           In April 1989, BPA; National Marine Fisheries Service; U.S. Fish and
                           Wildlife Service; five Indian tribes; and the states of Idaho, Oregon, and
                           Washington signed a regional fish bypass agreement that provides for
                           spilling water over the spillways of four dams until December 1998,
                           including The Dalles and Ice Harbor, to allow juvenile fish to pass unless
                           effective submerged traveling-screen bypasses are installed. The Corps
                           Division declined to sign the agreement, arguing that (1) the spill was
                           unjustified and (2) increased spillage may have infringed on other Corps
                           responsibilities, such as providing water for irrigation and navigation.
                           However, the Corps plans to continue to implement spill measures
                           within the parameters of the spill agreement as long as there are no
                           unacceptable impacts.

                           “Changing the same assumptions for the proposed    bypass at Lower Monumental Dam would likewise
                           increase the estimated benefits, and would therefore not change the Corps’ conclusion in favor of this
                           bypass.



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                                                                                                          --
                                    The regional spill agreement had not been signed at the time of the Divi-
                                    sion’s benefit and cost analysis of The Dalles and Ice Harbor bypass
                                    facilities. According to a Division official, they did not include the ben-
                                    efit of avoided spill in the analysis because (1) they did not consider
                                    spilling water to assist fish migration to be an economically justified
                                    measure and (2) when the analysis was prepared, they were not spilling
                                    water for juvenile fish at the two dams. Division officials said they made
                                    this decision because they do not believe spill is an efficient way to
                                    bypass fish and they therefore disagree with having to include it in their
                                    analysis.

                                    At our request, the Division recalculated the estimated benefits and
                                    costs of proposed traveling-screen bypasses at The Dalles and Ice
                                    Harbor Dams. The Corps used the same methodology as in its 1988
                                    report except that it incorporated as a bypass benefit the value of
                                    spillage (called for in the agreement). By changing this one assumption,
                                    the analysis showed that the estimated benefits of traveling-screen
                                    bypasses at The Dalles and Ice Harbor Dams would exceed the estimated
                                    costs. Table 2.2 compares the analyses with and without the value of
                                    the avoided s~lll.~

Table 2.2: Comparison of Proposed
Bypass Projacts With and Without                                                                       Ratio of benefits to costs)’
Baneftt of Avoided Spill                                                                                                       Without
                                                                                                       With avoided            avoided
                                                                                                        spill benefit     spill benefit
                                    The Dalles                                                                     1.02                 0.43
                                    Ice Harbor                                                                     1.12                 0.47
                                    aAssumes that Ice Harbor bypass is completed in fiscal year 1993 and The Dalles In fiscal year 1996

                                    We believe the value of water currently spilled to assist fish migration
                                    should have been included in the Corps’ analysis because regional offi-
                                    cials suggest that water will be spilled as long as traveling-screen
                                    bypasses are not in place. Corps officials agreed that changing this one
                                    assumption would result ln the estimated benefits exceeaing the esti-
                                    mated costs for bypasses at Ice Harbor and The Dalles Dams. However,
                                    they stated that any subsequent analysis should take into account




                                    40fficials in the region not4 that while the Spill Agreement expires in foal year 1999, there is a
                                    strong possibility that additional spill will continue as needed; consequently, the analysis included a
                                    SO-year period since this is the expected useful life of the bypasses.



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                          revised engineering estimates, which could result in the estimated costs
                          again exceeding the benefits for The Dalles and Ice Harbor bypasses.’


Differing Va.lues Among   Because the Division’s version of FISHPASS does not distinguish between
Fish Stocks               different fish stocks, the estimated benefits do not recognize that certain
                          stocks may have a higher value than others. Fish stocks are differenti-
                          ated on the basis of their spawning ground location. FISHPASS assigns
                          each species of fish a dollar value based on the combined commercial
                          and sport values of the species; thus, all stocks of a particular species
                          are valued equally.

                          However, as noted by the regional groups, circumstances may suggest
                          that a particular fish stock should be assigned a higher value. For
                          example, due in part to the migration difficulties imposed by the dams,
                          fewer fish return to spawning beds in the Snake River than to those
                          located just above or below Bonneville Dam on the Columbia River.
                          Thus, additions to a particular fish stock with spawning grounds in the
                          Snake River might be valued higher, from a cultural or aesthetic stand-
                          point, because of its scarcity.

                           For example, in March 1990, the Shoshone-Bannock tribe petitioned the
                           Secretary of the Interior to list the Snake River sockeye salmon as an
                           endangered species, and in May 1990 Oregon Trout, a public interest
                           group, petitioned for rules to list Snake River spring, summer, and fall
                           chinook and lower Columbia River coho salmon. Because the Corps did
                           not distinguish among stocks, potentially threatened or endangered spe-
                           cies were not afforded a higher value than that assigned to all other fish
                           on the basis of sport or commercial values.


Value of Noneconomic       Corps engineering regulations require that project analyses identify and
                           consider noneconomic factors, such as environmental effects, to the ful-
Benefits                   lest extent practicable. However, the Corps did not include noneconomic
                           considerations in its analysis of the proposed bypasses, stating that it
                           did not have a reliable way to place a value on them. While assigning
                           values is difficult, evidence suggests that such factors are applicable to
                           the proposed bypasses. Consequently, we believe the Corps’ analysis
                           should have incorporated them.


                           ‘For example, the Corps officials said that engineering analysis has shown that there is a reduction in
                           electrical generation when a traveling screen is placed in front of a turbine.



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A 1989 Corps survey suggests that both fishermen and nonfishermen in
the region derive an “existence benefit” from knowing there are fish in
the river. The Division initiated the survey to determine how much
people in the region would be willing to pay to double the number of fish
in the Columbia River. The results of this survey indicate that 54 per-
cent of the nonfishermen and 88 percent of the fishermen are willing to
pay higher electricity bills to double the size of the fish populations. The
users and nonusers stated they would be willing to pay, through higher
electric bills, a combined average of $68.49 per year to double the fish
runs.

In addition, Indian tribes attribute ceremonial, cultural, and religious
significance to salmon and steelhead in the Columbia River. For the
value of the expected harvest of fish by Indian tribes, the Division used
the fishes’ commercial value, because the majority of the fish caught by
Indians are sold through commercial channels. In the Indians’ view,
according to the Director of the Columbia River Intertribal Fish Commis-
sion, this does not reflect the full value of the fish to their way of life
and view of the world. He said the Indians believe that no economic
value could ever justify the damage done to the Northwest fisheries.
They are especially concerned about particular fish stocks that have
been important to them and now are badly depleted by the effects of
 dams, overfishing, and other factors. They consider the value of a pro-
ject that restores these depleted stocks to be much greater than the eco-
nomic value of fish added to already abundant parts of the fishery. (For
 additional regional comments on noneconomic factors, see app. I.)

We believe the Corps could have done more to consider noneconomic
values, such as those mentioned above, in its analysis, even if attaching
a precise dollar value was not feasible. The estimate of project effects
could have focused on particular fish stocks where nonmonetary values
might be quite high. The total value of additional fish in these key loca-
tions, such as stocks in Idaho, could be well above the average system-
wide value for sport and commercially caught fish. Once effects that
have significant nonmonetary values are identified, generally accepted
project analysis principles exist that can provide guidance for deciding
whether the investment is justified. The Corps’ own engineering regula-
tions provide guidance on accommodating nonmonetary values in an
analysis.

Although the Division and Portland District analyses showed that the
costs of proposed bypass facilities at The Dalles and Ice Harbor Dams
would exceed their benefits, the differences were comparatively small;


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                            Chapter 2
                            Limitations in Benefit Analysis and Regional
                            Involvement   Raise Questions About Corps
                            Bypass Decisions




                            for example, the estimated excess annual cost of a bypass at The Dalles
                            was $246,000. In this situation, recognizing the value of noneconomic
                            benefits would have provided a basis for an informed judgment about
                            whether the noneconomic values would be worth at least as much as the
                            excess costs.


                            Regional fish and wildlife agencies and Indian tribes were not ade-
The Corps Gave              quately involved in the Corps planning reports that determined whether
Limited Consideration       the traveling-screen bypasses at The Dalles and Ice Harbor Dams should
to Others’ Views            be recommended for Corps funding. Corps headquarters officials stated
                            that because these studies were outside its normal planning process,
                            public involvement was not required. However, because the studies were
                            used to make a decision about the bypasses, we believe that the Corps
                            should have involved the groups with an interest in the bypasses.


Requirements for            Corps engineering regulations provide that state and local participation
                            in Corps planning studies shall be encouraged throughout the planning
Coordination Wit1I          process. Specifically, the engineering regulations provide for the
Interested Parties          following:

                        . Planning studies are to be conducted in an open atmosphere to attain the
                          understanding, trust, and mutual cooperation of the public, including
                          state and local governments and Indian tribes, and must provide the
                          public with opportunities to participate throughout the planning
                          process.
                        . An effective public involvement strategy must be developed and imple-
                          mented, and the final report must discuss how the information gained
                          from the public was used in the planning process.
                        . Full consideration must be given to reports and recommendations fur-
                          nished by the U.S. Fish and Wildlife Service, National Marine Fisheries
                          Service, and state fish and wildlife agencies as required by the U.S. Fish
                          and Wildlife Coordination Act.

                             In addition, the Corp is required by the Pacific Northwest Electric Power
                             Planning and Conservation Act (the Northwest Planning Act) to coordi-
                             nate its actions with the Department of Interior, National Marine Fish-
                             eries Service, and appropriate state fish and wildlife agencies, to the
                             greatest extent practicable. While the Corp must also take into account
                             the Council’s program to the fullest extent practicable, the Corps is not
                             required to implement the Council’s recommendations.



                             Page 23                                  GAO/RCEtHO-180Columbia River Basin Fish Bypasses
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Corps Made Limited           Since 1986, four Corps reports have dealt with the issue of constructing
Coordination Efforts on      traveling-screen bypasses at The Dalles and/or Ice Harbor Dams. Three
                             of the four reports concluded that the traveling-screen bypasses should
Bypass Studies               not be constructed; one found that bypasses could be justified at Ice
                             Harbor Dam, but it was not made available to the public. In preparing
                             the first two reports, the Corps did not involve the Council, fish and
                             wildlife agencies, Indian tribes, or the public. For the third, the Corps
                             requested the Council to provide written comments on the need for
                             building additional bypasses on the Columbia and Snake Rivers. How-
                             ever, the Council did not believe this was adequate involvement. The
                             Corps did solicit and receive public comments on a draft version of the
                             fourth report but did not substantially change the report’s overall
                             conclusions.

Lower SnakeRiver Study       The Lower Snake River Study,‘j prepared by the Corps’ Walla Walla Dis-
                             trict office, investigated the feasibility of installing traveling-screen
                             bypasses at Lower Monumental and Ice Harbor Dams. The report’s ben-
                             efit and cost analysis showed that traveling screens could be justified at
                             these two dams. Officials from the Council, U.S. Fish and Wildlife Ser-
                             vice, and the National Marine Fisheries Service told us they were una-
                             ware of the study until we brought it to their attention. Walla Walla
                             District officials confirmed that no one outside the Corps had been
                             involved in this study and that it had not been released since it was
                             considered an internal study.

GoalsReport and 1988Bypass   The Goals Report’ and the 1988 Bypass Report8 concluded that trav-
Report                       eling-screen bypasses should be constructed at Lower Monumental Dam,
                             but not at Ice Harbor and The Dalles Dams. Both reports were made
                             available to interested parties only after they were completed. The
                             Goals Report was prepared by the Division, and the 1988 Bypass Report
                             was prepared by a team from Army and Corps headquarters.

                             The Corps did not allow others to participate in preparation of the Goals
                             Report even when asked. In a September 23, 1987, letter, the Columbia
                             River Intertribal Fish Commission asked that Corps headquarters direct
                             the Division to consult with the Commission in preparing the report. The
                             letter explained that the Commission had made a similar request to the

                             “Lower Snake River Juvenile Fish Guidance Efficiency Study, Incremental Economic Analysis. Recon-
                             naiasance Report, April 17, 1986.

                             ‘Juvenile Fish Bypass Goals, April 4,19SS.

                             *Report on the Columbia River Fish Bypass Program, July 22, 1988.



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Division, which had denied the request on the basis of directions from
headquarters. The letter stated that the tribes, as co-managers of the
fishery resources in the Pacific Northwest, could provide meaningful
input to the development of fish passage goals.

On October 14, 1987, Corps headquarters advised the Commission:

At the present time, a working draft of the report is being reviewed by the staff here
in Washington. We have always had every intention of sharing the report with you,
the Federal and state resource agencies, and all other groups that have an interest in
the fish bypass program. However, I believe it would be inappropriate to release the
report while it is still under review within the Corps. I am sure you can appreciate
the confusion that could result if the report was revised while you were reviewing
the original draft. When our review of the report is complete and we have developed
a Corps of Engineers position on the issues, we plan to fully coordinate the report
with you and all other interested parties. [Underscoring supplied]

A Division official stated that the final Goals Report was issued to the
public on April 14, 1988, without prior involvement or review by inter-
ested parties. On June 28, 1988, the Columbia Basin Fish and Wildlife
Authority provided 15 pages of comments to the Division on the Goals
Report. The Corps did not respond; a Corps official advised us that this
lack of response was an oversight.

On July 6, 1988, the Council provided comments on the final report, and
on August 29, 1988, the Division responded in part as follows:

One concern mentioned in your letter was the lack of Council participation in prepa-
ration of the report. I want to emphasize that the Goals Report was prepared as an
internal discussion paper intended to look at the incremental economic benefits of
the bypass options under consideration. We fully intend to coordinate the project-
specific reports with the regional resource, power, and planning agencies.

The Division’s detailed response was primarily a rebuttal to the
Council’s comments. The Corps made no revisions to the Goals Report
based on the specific comments made.

The 1988 Bypass Report, prepared by a team from Army and Corps
headquarters, essentially affirmed the conclusions of the Goals Report.
On June 20,1988, the Corps team working on the 1988 Bypass Report
asked the Council to provide comments by July 6, 1988, on the need for
the bypasses. The Council responded on July 6, 1988. Council officials
stated that this was not adequate involvement in the study. They also
said they did not even see the report until it was issued in final.



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1989DailiesReport             According to a Division official, the only project-specific report on The
                              Dalles or Ice Harbor Dams since the Goals Report concerned a study,
                              begun in 1984, of juvenile fish passage at The Dalles Dam. On January
                              12, 1987, the Corps’ Portland District requested comment on the draft
                              report, which did not recommend funding a traveling-screen bypass at
                              The Dalles. The report showed, of the options considered, that trans-
                              porting juvenile fish from John Day Dam to a location below Bonneville
                              Dam had the highest net benefits;” however, additional studies were rec-
                              ommended to answer unresolved issues.

                              The Portland District provided the draft to interested parties and asked
                              for comments. On January 30, 1987, the U.S. Fish and Wildlife Service
                              replied to the draft and stated in part:

                              No consultation with the fish and wildlife agencies and Indian tribes was provided
                              during the development of this report and the short comment period has not pro-
                              vided sufficient time for a detailed review of the document. Consultation should
                              have occurred during the report development and more time should have been pro-
                              vided for detailed review to ensure that the report provides a complete and accurate
                              evaluation of alternative juvenile fish collection-bypass facilities at The Dalles Dam.

                              Comments were also received from the Columbia River Intertribal Fish
                              Commission, the State of Idaho, Bonneville, and National Marine Fish-
                              eries Service.

                              The agency comments and the Corps rebuttals were included in the
                              March 1989 final report,‘0 but the Corps did not substantially change the
                              overall report conclusions. The estimated benefits did not exceed the
                              costs for submerged traveling screens and they were not recommended
                              for construction, but additional studies were recommended. The report
                              also concluded: “Only the John Day transport appears economically
                              viable.”


Corps Officials Stated That   Corps headquarters officials advised us that for normal Corps planning
Engineering Regulations       studies, interested parties, the public, and government agencies are
                              involved from the beginning. They said, however, that these four studies
Did Not Apply to Studies      were either internal (the case for the first three reports) or were outside
                              the normal Corps planning process (the case for The Dalles General


                               “Net benefits are computed by subtracting the cost of a proposed project from its total estimated
                               benefits.

                               “‘General Letter Report-Juvenile   Fish Passage, The Daks Dam, March 1989.



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                  Letter Report.) Consequently, the Corps does not believe the engineering
                  regulations were applicable and did not seek involvement of other
                  parties.

                  We believe it is clear that the Corps used the studies to make decisions
                  about the proposed bypasses. Consequently, we believe the Corps
                  should have done more to promote public understanding, trust, and
                  cooperation regarding the proposed bypass facilities.

                  Officials from the Council, Fish and Wildlife Service, and National
                  Marine Fisheries Service told us that they believed the Corps’ effort to
                  involve others was inadequate for the four reports. The officials also
                  stated that their agencies should be involved from the beginning of a
                  study. In their view, to provide comments on a draft report is not ade-
                  quate involvement.


                  While benefit and cost analysis can be a useful technique to help make
Conclusions       decisions, the results in this instance were not a sufficiently clear basis
                  for the Corps’ decision not to construct bypasses at The Dalles and Ice
                  Harbor Dams. The Corps did not sufficiently take into account the limi-
                  tations of the FISHPASScomputer model used in the analysis. In addition,
                  the analysis was sensitive to underlying assumptions; for example, had
                  the benefit of avoided spill been included and had noneconomic consid-
                  erations, although difficult to quantify, been considered, the estimated
                  benefits would have exceeded the estimated costs. Further, the Corps’
                  decision not to include other parties in the bypass studies was not
                  appropriate given the Corps’ use of the studies to make a decision
                  important to others in the region.

                  Also, while the Corps decided that it was not obligated to include other
                  parties in the studies leading to its decision against building traveling-
                  screen bypasses at The Dalles and Ice Harbor Dams, it is clear that its
                  planning was not characterized by the spirit of public involvement
                  called for by engineering regulations.


                  Because the Congress has authorized the Corps to plan and construct
Recommendations   bypasses at Ice Harbor and The Dalles Dams, we are not recommending
                  that the Corps prepare new estimates of their costs and benefits. How-
                  ever, if estimates of the benefits of proposed projects for increasing the
                  survival of juvenile fish in the Columbia River Basin are made in the



                  Page 27                                 GAO/WED-B@lsO   Columbia   River Basin Fish Bypasses
    Chapter 2
    Limitations in Benefit Analysis and Regional
    Involvement   Raise Questions About Corps
    Bypass De&ions




    future, we recommend that the Secretary of the Army direct the Chief,
    Corps of Engineers, to

. use validated models that can identify the degree of uncertainty or pro-
  vide a probability range;
l recognize the impact of avoiding water spilled to assist fish migration, if
  such spill is an existing practice;
. consider the status of stocks in addition to species of fish;
l consider the value of intangible factors, quantified to the fullest extent
  practicable, in the decision-making process, and
. consult with the Council, fish and wildlife agencies, Indian tribes, and
  other interested parties in carrying out these actions.




     Page 28                                 GAO/RcED9O-180   Columbia   River Basin Fish Bypasses
Chapter 3

Fish Bypass Decision-MakingIs Hamperedby
Lack of SpecificObjectivesand Data on
Bypass Effectiveness
                             The controversy over the Corps’ decisions against constructing trav-
                             eling-screen bypasses at The Dalles and Ice Harbor Dams is indicative of
                             an underlying issue: the Corps is not obligated to restore Columbia River
                             Basin anadromous fish populations to a specific level. Consequently, the
                             Corps has been unable to analyze proposed projects on the basis of their
                             contribution to a specific mitigation goal, regardless of the magnitude of
                             costs or benefits. Establishing a mitigation goal may be difficult, but the
                             lack of such a goal hampers project analyses and contributes to uncer-
                             tainty over the Corps’ budget.

                             The ability to make decisions about the proposed traveling-screen
                             bypasses is further hampered by a scarcity of information about their
                             effectiveness in changing the survival of migrating fish. The limited
                             information available about existing bypasses is inconclusive regarding
                             their effectiveness for facilitating the downstream migration of juvenile
                             fish, and thus for increasing the numbers of returning adult fish.


                             Over the years, the Corps has undertaken many projects to mitigate for
While Difficult to           damages to fisheries caused by the Corps’ dams; some of these are dis-
Establish, Mitigation        cussed in chapter 1 of this report. However, according to Corps officials,
Objective Would              the extent to which the eight Corps dams have contributed to declines in
                             fish runs has never been fully determined, and the extent of the Corps’
Provide Benefits             remaining obligation to further increase the fish runs is unknown. Thus,
                             the Corps does not know if prior mitigation efforts are sufficient or if
                             more needs to be done.

                             The Corps, other agencies, and Indian tribes involved in the controversy
                             over traveling-screen bypasses agree that a specific mitigation objective
                             is needed. Further, officials from the Corps and the Office of Manage-
                             ment and Budget (OMB) have recognized that establishing a specific miti-
                             gation objective will help determine future funding levels. With a
                             specific objective established, the Corps can base project construction
                             decisions on the projects’ contribution to achieving any portion of the
                             objective which has not yet been met.


Establishing Mitigation      Establishing the Corps’ mitigation objective may be difficult. Corps offi-
                             cials believe complete data on the Columbia and Snake Rivers’ fish runs
Objective May Be Difficult   prior to construction of the dams do not exist. In addition, the size of
                             runs prior to the dams may not represent a realistic goal because the
                             rivers’ characteristics may have changed to the point that they can no
                             longer handle migrations of that size.


                             Page 29                         GAO/RCED-90-190   Columbia   River Basin Fish Bypasses
                               Chapter 3
                               Fish Bypass Decision-Making   Is Hampered   by
                               Lack of Specific Objectives and Data on
                               Bypass Effectiveness




                               According to the Council, the dams have changed the rivers from fast-
                               flowing streams to a series of reservoirs. Whereas a juvenile fish could
                               migrate to the ocean in less than a month before the dams were built,
                               migration can now take two to three times as long depending on water
                               conditions. If the journey takes too long, juvenile fish may be physically
                               unable to adjust to salt water once they finally reach the ocean and thus
                               die. Also, a longer time in the river increases exposure to predation.

                               We believe that establishing a mitigation objective may also require deci-
                               sions on such matters as the following:

                           l Will the mitigation objective be based on the number of juvenile fish
                             surviving downstream migration, or will it be based on the number of
                             returning adult fish?
                           l If the objective is based on the survival of juvenile fish, should an objec-
                             tive exist for each dam, or for the river basin as a whole?
                           l Will the objective be expressed as an aggregate number of fish, or will it
                             be disaggregated by characteristics such as species or stock, geographic
                             location within the river basin, or classification as wild or hatchery-bred
                             fish?
                           . Whether based on juvenile or returning adult populations, should the
                             measure be taken daily or seasonally?


Corps, OMB Favor                In the 50 years since Bonneville Dam (the first major dam on the
Mitigation Objective for       Columbia) began operating, the Corps has spent about $300 million on
                                fish passage at its eight dams, about $100 million of it for downstream
Budgetary Reasons              juvenile passage. In addition, over $200 million has been spent on hatch-
                                eries and research. In June 1990, the Corps estimated that if all projects
                                currently proposed were built, including the bypasses at The Dalles and
                                Ice Harbor, the program would cost approximately another $233.9 mil-
                                lion over the next 10 years.

                               A Corps official stated that while justified fish bypass measures
                               installed in the past have received support in administration budgeting
                               as part of ongoing construction, federal deficits have changed this pic-
                               ture since 1987. OMB officials have expressed interest in establishing a
                               mitigation objective in order to determine the extent of federal responsi-
                               bility for funding additional projects. Similarly, the Assistant Secretary
                               of the Army for Management and Budget and other officials at Corps
                               headquarters told us they favor a study to help determine their
                               remaining mitigation objective.



                               Page 30                                 GAO/RCED-90-180   Columbia   River Basin Fish Bypasses
                              Chapter 3
                              Fish Bypass Decision-Making   Is Hampered    by
                              Lack of Specitic Objectives and Data on
                              Bypass Effectiveness




                              Establishment of a mitigation objective has received consideration in
                              proposed Corps budgets. OMB deleted from the budget for fiscal year
                              1990 funds the Corps had proposed for constructing bypass measures,
                              citing the need for a mitigation study. The administration’s proposed
                              fiscal year 1991 budget contained $1 million to start a 2-year mitigation
                              study. The Senate energy and water appropriations bill for fiscal year
                              1991 provides for the proposed mitigation analysis, but the House bill
                              directs the Corps to use the $1 million instead for additional study at Ice
                              Harbor Dam.


Establishing a Mitigati .on   Corps engineering regulations require that, when a mitigation objective
                              is established, a technique called incremental analysis must be used to
Objective Would Facili tate   evaluate specific projects. Incremental analysis involves (1) identifying
Project Analysis              all the measures, or increments, that could be taken to achieve the same
                              objective and (2) ranking them according to their cost effectiveness.
                              Using this approach, the most cost-effective increments (set of projects)
                              can be selected to meet the objective. This would provide the Corps and
                              Congress with a means for deciding how to assist downstream fish
                              migration in the most effective manner.

                              Incremental analysis may require selecting measures whose individual
                              benefits, in a strict economic sense, do not match their costs since
                              noneconomic benefits are also required to be considered. Thus, this
                              approach could result in selecting construction of bypasses at The Dalles
                              and Ice Harbor, as long as they were determined to be the most cost-
                              effective alternative for meeting the objective, even if their economic
                              benefits were not shown to be greater than their costs.


                              Our review of the Corps’ project analysis revealed that little information
Bypasses’ Effect on           is available about the survival effectiveness of traveling-screen
Juvenile Fish survival        b ypasses, which further hampers decisions as to whether or not the pro-
Is Inconclusive               posed bypasses should be constructed. The limited information that has
                              been collected paints an inconclusive picture as to whether bypasses
                              have a significant effect in raising the survival rate of juvenile fish
                              migrating downstream and the number of returning adults.

                               Numerous studies have been conducted of existing traveling-screen
                               bypasses at Corps dams on the Columbia and Snake Rivers. These
                               studies have dealt with how many fish are being guided into the bypass
                               and the condition of the fish after using the bypass. However, Corps,
                               National Marine Fisheries Service, and U.S. Fish and Wildlife Service


                               Page 31                                    GAO/RCED9@180   Columbii   River Basin Fish Bypasses
                              Chapter 3
                              Fish Bypass Decision-Making   Is Hampered    by
                              Lack of Specific Objectives and Data on
                              Bypass Effectiveness




                              officials could identify only two studies that have been done that
                              directly compare at the same dam the survival of salmon using the
                              various routes to get by a particular dam. Neither study has so far pro-
                               duced conclusive evidence that bypasses enhance the survival rate for
                              juvenile fish. A study at Lower Granite Dam indicated a lower survival
                               rate for fish using the traveling-screen bypass than for fish using other
                               means to get by the dam, such as the spillway or turbines. Preliminary
                               results from an ongoing study at Bonneville Dam have shown a higher
                               survival rate for juvenile fish going through the turbines than for juve-
                               nile fish using the traveling-screen bypass.


Lower Granite Dam Study       To determine the survival of the juvenile spring chinook salmon, the
                              Corps funded a study in 1986 at Lower Granite Dam. The objective of
                              the study, which was conducted by the National Marine Fisheries Ser-
                              vice, was to estimate the short-term survival and condition of (1) juve-
                              nile spring chinook salmon after passing through either the spillway, the
                              turbines, or the traveling-screen bypass and (2) a control group released
                              below the dam. Unfortunately, the number of recovered marked fish
                              was insufficient for complete analysis. However, the researchers’ report
                              made the following observations:

                          l   The survival of the fish released in the lower turbine area was approxi-
                              mately equal to the control group released below the dam.
                          l   Fish released into the traveling-screen bypass system appeared to have
                              sustained the highest mortality of all groups.


Bonneville Dam Study          Corps and fish and wildlife officials stated that no studies have been
                              completed on the survival effectiveness of the traveling screen in
                              increasing adult salmon and steelhead returns. However, one study is
                              currently ongoing at one of Bonneville’s two powerhouses. Begun in
                               1987, this is an El-year study composed of 3 years of juvenile fall chi-
                              nook salmon releases followed by a 5-year adult recovery period. The
                              study used hatchery fish that were released in the summer. The prin-
                              cipal National Marine Fisheries Service biologist stated that preliminary
                              data on returning adults will be available in March 1990 and each year
                              thereafter until the recovery period has been completed.

                               In 1987 there were four release points: the upper and lower turbine
                               intakes, the traveling-screen bypass, and 2.5 kilometers downstream
                               from Bonneville’s second powerhouse. In 1988 and 1989 an additional
                               release point was made just below the dam. Short-term comparative


                               Page 32                                    GAO/RCEDW-180   Columbia   River Basin Fish Bypasses
                  Chapter 3
                  Fish Bypass Decision-Maldng   Is Hampered   by
                  Lack of Specific Objectives and Data on
                  Bypass Effectiveness




                  juvenile survival analyses were then made on the basis of juvenile
                  salmon recoveries 167 kilometers downstream from Bonneville dam.

                  Combined recovery data for all 3 years showed a statistically significant
                  decreased survival rate for juveniles released into the traveling-screen
                  bypasses compared to those going through the turbines. There was a 9
                  percent difference between the turbines and bypass. The actual impact
                  on adult returns, however, will not be known until adult return data are
                  available and the analysis is completed.

                  The Corps made several inspections of the traveling-screen bypasses in
                  1987 and 1988 and found no major physical problems with them. The
                  principal National Marine Fisheries Service biologist on the study
                  advised us that the reasons for the low traveling-screen bypass survival
                  rate could be problems in the bypass itself; the location where the
                  bypass returns the fish to the river, allowing predator fish to eat a large
                  number of juveniles; or downstream mortality because of predators and
                  increased stress from going through the bypass. He believed the problem
                  is probably predation resulting from a problem in the bypass that
                  affects the fish downstream. He also cautioned that the results could be
                  different for other species with different release dates.

                  The National Marine Fisheries Service has proposed a l-year study to
                  identify the reason for the problem. The Corps has approved funding for
                  the study and expects it to begin in 1990.


                  The controversy surrounding the need to build additional traveling-
Conclusions       screen bypasses at the Corps’ dams could be repeated in the absence of a
                  specific Corps mitigation objective for the remaining unmitigated dam-
                  ages to anadromous fish populations in the Columbia and Snake Rivers.
                  Without a mitigation objective, the Corps and Congress cannot (1) deter-
                  mine the budgetary needs for additional mitigation projects or (2) know
                  which measures provide the most cost-effective assistance to down-
                  stream fish migration.


Recommendations   Engineers, in consultation with the Council, fish and wildlife agencies,
                  Indian tribes, and other interested parties, to (1) establish a mitigation
                  objective for damage to anadromous fish populations in the Snake and
                  Columbia Rivers and (2) determine which measures, such as bypass



                  Page 33                                 GAO/RCED9!%180   Columbia   River Basin Pish Bypasses
                       Chapter 3
                       Fish Bypass Decision-Msking   Ia Hampered   by
                       Lack of Specific Objectives and Data on
                       Bypass Effectiveness




                       facilities, are necessary to meet this objective. The objective should be
                       specific in terms of how the fish populations will be measured.


                       Establishing a mitigation objective would not necessarily result in a con-
Options for            elusion to construct bypasses at The Dalles and Ice Harbor Dams.
Consideration by the   Rather, under the incremental analysis approach called for in Corps
Congress               engineering regulations, a decision in favor of the traveling-screen
                       bypasses would depend on determining that they are among the most
                       cost-effective measures needed to meet the objective. This determination
                       is made more complex by the lack of data as to whether fish bypasses
                       actually produce benefits at their anticipated level. As discussed in this
                       chapter, studies to date have not established that the bypasses are
                       effective in increasing the numbers of surviving juvenile fish migrating
                       downstream, and thus the numbers of returning adult fish.

                       In light of these findings, the Congress appears to have three main
                       options with regard to considering bypass facilities at Lower Monu-
                       mental, The Dalles, and Ice Harbor Dams.

                       1. Directing the Corps to proceed with planning and constructing the
                       traveling-screen bypasses as currently authorized, irrespective of a spe-
                       cific mitigation objective or further study of bypass effectiveness. This
                       option could result in completing design and/or construction of the
                       bypasses before the final results are available from the current bypass-
                       effectiveness study at Bonneville Dam; thus, it carries the risk that sub-
                       stantial sums may be spent to plan and build bypasses that are subse-
                       quently found to be ineffective. Further, a specific mitigation objective
                       and incremental analysis could conclude that not all of the bypasses are
                       warranted.

                       2. Directing the Corps not to proceed with planning and constructing the
                       traveling-screen bypasses until the Corps has established an agreed-
                       upon mitigation objective and, through incremental analysis, determined
                       that the bypasses are cost effective. This option, unlike the first, would
                       provide assurance that the bypasses were needed to mitigate losses
                       caused by the Corps dams. However, like the first option, it carries the
                       risk that substantial sums may be spent to plan and build facilities that
                       later are found not to be as effective as other alternatives.

                       3. Directing the Corps to postpone construction of the traveling-screen
                       bypasses until completion of (1) the mitigation study and (2) additional
                       research on the effectiveness of bypasses and other factors that affect


                       Page 34                                 GAO/RCRD9@180Columbia River Basin Fish Bypasses
Chapter 3
Fish Bypass Decision-Making   Is Hampered   by
Lack of Specific Objectives and Data on
Bypass Effectiveness




juvenile fish passage and survival. This additional research could
 include the ongoing Bonneville Dam study and, if deemed necessary,
other studies examining bypass effectiveness. If a mitigation study con-
 cludes that additional mitigation is not warranted, this option would
 avoid unnecessary expenditure of funds. If further mitigation is war-
 ranted and the bypass research is conclusive, this option would help to
 ensure that funds expended for the bypasses would best aid down-
 stream migration of juvenile fish. However, if the research is not conclu-
 sive, this option carries with it the risk that, after several years’ delay,
 the Congress could face the same decision with little or no additional
 information. In addition, further delay could adversely affect stocks in a
 critical condition. As noted in chapter 2, groups have petitioned the Fish
 and Wildlife Service to place several species of Snake and Columbia
 River fish on the list of endangered and threatened species.




Page 35                                 GAO/RCEDSl%lSO   Columbia   River Basin Fish Bypasses
Appendix I

Consolidationof F’ishand Wildlife Agencies’,
Indian Tribes’, and the Council’sConcerns;
Corps’ Responses;And GAO’sObservations
                             This appendix contains detailed concerns raised by the Council, fish and
                             wildlife agencies, and Indian tribes, about various aspects of the Corps’
                             consideration of traveling screen bypasses. Those concerns were
                             expressed in correspondence among the Chairman of the House Com-
                             mittee on Energy and Commerce, the Council, fish and wildlife agencies,
                             Indian tribes, BPA, and the Corps. We discussed this consolidated list of
                             concerns with the groups and agencies expressing the comments to
                             ensure that it accurately reflected their views.

                             The Corps’ responses were obtained from discussions with North Pacific
                             Division (Division) officials which they, officials from the Portland and
                             Walla Walla Districts, and headquarters officials subsequently reviewed.
                             All changes suggested by Corps officials have been incorporated into the
                             responses. Our observations are based on our analysis of Corps’ reports
                             and other documents, and discussions with our consultant and officials
                             from the Corps, the Council, BPA, and the University of Washington.


Concern 1: Compliance        The Corps is at odds with the spirit, if not the letter, of the Northwest
With the Spirit of the Act   Planning Act.

                             Corps Response: The Corps is required to comply with the act “to the
                             fullest extent practicable.” The Corps believes it has done that.

                             GAO Observation: The Corps must consider the program adopted by the
                             Council under the Northwest Planning Act “to the fullest extent practi-
                             cable” in the decision-making process. The Corps has not accepted the
                             Council’s interim goal of doubling the fish runs or any part of that goal
                             as its mitigation objective. The Corps maintains that it will provide mea-
                             sures for the improved passage of fish at individual dams if the mea-
                             sures can be justified through its studies.


Concern 2: Delays            The Corps has had a history of delays in implementing fish improve-
                             ments even though the Northwest Planning Act specifically provides for
                             improved survival of fish at hydroelectric facilities. The following are
                             examples of concerns about delays.

Concern2a                    The conflict between Corps headquarters and the Division ovrer the
                             Goals Report (final report dated April 4, 1988) caused a delay in the
                             allocation of appropriated funds for Corps-supported projects at Little
                             Goose, McNary, Lower Granite, and Lower Monumental Dams in fiscal
                             years 1988 and 1989. Also, any delay in spending authorized design


                             Page 36                         GAO/RCED9@180   Columbia   River Basin Fish Bypasses
                          Appendix I
                          Consolidation   of Fish and Wildlife Agencies’,
                          Indian Tribes’, and the Council’s Concerns;
                          Corps’ Responses; And GAO’s Observations




                          funds for The Dalles and Ice Harbor Dams will further delay actual con-
                          struction of bypass facilities.

                          Corps Response: There was no conflict between Corps headquarters and
                          the Division. Congressional funding was delayed as a result of differing
                          interpretations of congressional committee language. Since that differ-
                          ence was resolved by the administration and the Congress, design funds
                          have been spent at all the projects in accordance with congressional
                          language.

Concern 2b                All juvenile fish bypass systems currently in place on the Snake and
                          Columbia Rivers were constructed or approved before the Council
                          adopted its first Fish and Wildlife Program in 1982. The April 1988
                          chartering of an Army team to review the Corps’ fish bypass program
                          occurred 3-l/2 years after the Council’s 1984 Fish and Wildlife Program
                          required the development, testing, and installation of bypass systems
                          and 14 months after the Council’s 1987 Program Amendment, which
                          added a specific schedule, based on Corps input, for bypass develop-
                          ment. The Corps did not request adequate funds in its budget for plan-
                          ning and design of needed juvenile fish bypass facilities in fiscal years
                          1986-90.

                          Corps Response: The Corps has supported making improvements for the
                          survival of fish at hydroelectric facilities when its benefit and cost anal-
                          ysis showed such improvements were justified. When such improve-
                          ments were not justified on this basis, the Corps did not recommend
                          them for funding. Any perceived delays on the Corps’ part are because
                          of differences in the Corps’ and others’ ideas about what is sufficient
                          information to justify funding for projects. The Corps had, in fact, car-
                          ried out most of the mitigation required for its dams before the Council
                          was established. The justification for the remaining measures is much
                          less certain.


Concern 3: Coordination   Regional parties have not been adequately involved, as is required by
With Interested Parties   Corps planning engineering regulations, in the Corps’ economic analysis
                          prepared for the (1) Goals Report and (2) The Dalles Report.

                          Corps Response: For Corps planning studies, the interested parties, the
                          public, and other government agencies are involved from the beginning.
                          Some of the Corps’ studies on bypass improvements were internal budg-
                          etary documents and were not considered part of the normal planning
                          process. Consequently, the Corps was not required to coordinate lvlt h


                          Page 37                                    GAO/RCED-SO-180   Columbia   River Basin Fish Hg passes
                             Appendix I
                             Gmsolidation   of Fish and Wildlife Agencies’,
                             Indian ‘bib’,   and the Cooncil’s Ckmcerns;
                             Corps’ Responses; And GAO’s Observations




                             other parties. Also, the Corps did not have much time to coordinate
                             because of deadlines. The Dalles study, however, was a general letter
                             report and was coordinated to some extent, but not to the full extent,
                             with other parties from the beginning.

                             GAO Observation: A Corps Engineering Regulation (ER- 1105-2-50) pro-
                             vides that state and local participation in addressing fish and wildlife
                             resources shall be encouraged throughout the Corps’ planning process.
                             The Corps’ decision that it was not obligated to include other parties in
                             its studies leading to its decision against building bypasses at The Dalles
                             and Ice Harbor Dams added to the concerns raised by local agencies,
                             tribes, and others. The Corps did ask for and receive comments on The
                             Dalles draft report.


concern 4: Benefit-to-Cost   Benefit-to-cost analysis should not be the criterion for fish and wildlife
                             mitigation decisions. The Congress, in enacting the Northwest Planning
Analyses                     Act, specifically considered and rejected the use of benefit/cost analyses
                                   _
                             as a prerequisite for mitigation measures. (16 USC. Section 839
                             (h)(G)(C).) Also, the Water Resources Development Act, P.L. 99-662,33
                             U.S.C.A. Section 2284 (1987), expressly deems the benefits of fisheries
                             mitigation measures to be equal to their cost. Congress took this
                             extraordinary step because of frustration that benefit/cost analyses
                             were being used to thwart fish and wildlife and related mitigation. The
                             Corps’ Water Resources Council’s Principles and Guidelines are not
                             applicable to the analyses of bypass system economic considerations.
                             Mechanical fish bypass facilities are measures to mitigate the impacts of
                             water resource projects and are not themselves water resource projects.

                             Corps Response: A positive economic benefit-to-cost ratio is not required
                             for &stifiiation of all increments to a water resource project. What is
                             required is incremental justification of each element. Incremental justifi-
                             cation means that the benefits (both monetary and nonmonetary) of a
                             project increment exceed the costs (both monetary and nonmonetary) of
                             adding that increment to the plan.

                             The Corps recognizes that all benefits of a project may not be easily
                             quantifiable in economic terms, and this should be considered in an
                             incremental justification. But each increment to be included in a plan
                             must be incrementally justified on a monetary and/or nonmonetary
                             basis.




                              Page 38                                   GAO/RCEIHO-180   Columbia   River JSasin Fish Bypasses
                          Appendix I
                          Consolidation   of Fish and Wikilife Agencies’,
                          Indian Tribes’, and the CoonciI’s Concerns;
                          Corps’ Responses; And GAO’s Observations




                          The Goals Report identified the monetary costs and benefits associated
                          with each of the proposed bypass measures. This was done by identi-
                          fying the incremental monetary benefits and costs of each measure;
                          therefore, it could be considered a limited incremental justification as
                          discussed above. The shortcomings of this incremental analysis were
                          that it did not include the nonmonetary benefits because they were not
                          easily identifiable, and it did not include the mitigation planning objec-
                          tive. The Corps is responsible for identifying the adverse effects which
                          may be caused by the construction and operation of its dams. The Corps,
                          however, is not required to mitigate all adverse effects resulting from
                          completed projects, and the Council’s fish and wildlife program is not
                          binding on the Corps.

                          GAO Observation: P.L. 99-662,33 U.S.C., states that in the evaluation of
                          a water resources project,

                          . the benefits attributable to measures included in a project for the purpose of
                          environmental quality, including improvement of the environment and fish and
                          wildlife enhancement, shall be deemed to be at least equal to the costs of such
                          measures.

                          Corps engineering regulations require incremental analysis for mitiga-
                          tion-related projects rather than benefit and cost analysis. These Corps
                          engineering regulations, however, do require that the monetary and non-
                          monetary benefits of an individual mitigation increment exceed the
                          costs of adding that increment to the plan. Increments are added to the
                          plan until the mitigation planning objective has been achieved or until
                          increments become too costly. Incremental analysis provides that those
                          increments with the lowest cost should be implemented first, providing
                          they obtain the same objective. However, the Corps is not precluded
                          from using a benefit and cost analysis.


Concern 5: Who Pays for   The Corps’ analysis does not recognize that, since BPA will repay most of
                          the fish bypass costs, they are not really a cost to the federal
Bypass Activities?        government.

                          Corps Response: The bypass activities are a cost to the federal govern-
                          ment. The design and construction funds come from the federal Trea-
                          sury. Northwest ratepayers repay the Treasury over a long period of
                          time. Only if the ratepayers paid for the bypasses up front would there
                          be no federal cost.



                          Page 39                                     GAO/RCED-90-180   Columbia   River Basin Fish   Bypasses
                          Appendix I
                          Consolidation       of Fish and Wildlife     Agencies’,
                          Indian   Tribes’,   and the Council’s      Concerns;
                          Corps’ Responses; And GAO’s Observations




                          GAO Observation: Bypass funding is a cost to the federal government. As
                          long as the Corps incurs costs for mitigation purposes, regional rate-
                          payers through BPA will reimburse the U.S. Treasury. According to a BPA
                          financial analyst, BPA must repay the Treasury with interest at a rate
                          current at the time of the loan. In April 1990, current Treasury rates
                          were between 9 and 10 percent. The length of time to repay depends
                          upon how many years remain of the dam’s expected 50-year life.


Concern 6: The FISHPASS   The Corps consulted with fish agencies and tribes in the early develop-
Model                     ment of the FISHPASSmodel that was subsequently used in the economic
                          analysis for the Goals and Dalles reports, but did not resolve or incorpo-
                          rate their concerns and recommendations.

                          Corps Response: FISHPASSwas the best available analytical tool at the
                          time. Because of the need to meet deadlines, the Corps was unable to
                          make many changes at the time of the analysis. The Corps received a
                          number of fish agencies’ and tribes’ concerns and recommendations
                          during the development of FISHPASSthrough the Council’s Mainstem Pas-
                          sage Advisory Committee. Some recommendations were not adopted,
                          such as the recommendation that the Corps not use computer modeling
                          or not use the results.

                           GAO Observation: The Corps attempted to coordinate its input parame-
                           ters with the Mainstem Passage Advisory Committee. According to the
                           former Chairman, the Mainstem Passage Advisory Committee was
                           established by the Council to obtain agreement among parties in the
                           region on parameter values to be used for modeling purposes to analyze
                           spill. However, they did not all agree to the parameter values.

                           The following are examples of other modeling concerns.

Concern6a                  The Corps did not have a peer validation of the model.

                           Corps Response: The Corps is working with BPA and the University of
                           Washington in a peer review of FISHPASS.The University of Washington
                           review will not validate/test the model against nature; it is not a reality
                           check.

                           GAO Observation: The Corps did not have the model independently
                           reviewed or calibrated, that is, results checked against the actual num-
                           bers of fish present in the rivers. BPA contracted with the University of
                           Washington for the review of both the Corps’ and BPA'S versions of


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            Appendix I
            Consolidation   of Fish and Wildlife Agencies’,
            Indian Tribes’, and the Council’s Concerns;
            Corps’ Responses; And GAO’s Observations




            FISHPASS However, the work did not include the portion of the Corns’
            model dealing with returning adult fish, since the ocean survival portion
            was based on scanty data.

Concern6b   (i) The FISHPASSmodel is an overly simplified abstract of a very complex
            natural system. Because of the limitations of available data, many
            assumptions were made in constructing FISHPASSthat add a great deal of
            uncertainty to the model outputs. The model may be useful in identi-
            fying information gaps or making gross comparisons or rankings of
            alternatives, but it is wholly inadequate as a predictive model for esti-
            mating the actual fish benefits of alternative bypass actions.

            (ii) FISHPASSuses point estimates for a number of parameters that vary
            within a very large range. Some of this variation reflects changes that
            occur in response to environmental factors or interaction with other
            parameters, and some reflect the precision (or lack thereof) of the
            methods of estimation. Given this weakness in basic model parameters,
            the model should not be relied on to predict fishery benefits because of a
            large uncertainty associated with the output results.

            (iii) The sensitivity analysis in the Goals Report does not address this
            fundamental weakness of the FISHPASSmodel. Instead, it assumes the
            predicted fishery benefits provided by FISHPASSare accurate and then
            evaluates the sensitivity of the analysis, using FISHPASSoutput, that was
            conducted for this report.

            Corps Response: (i) FISHPASSis useful for ranking alternatives. However,
            it is incorrect to say that F'ISHPASSis wholly inadequate as a predictive
            model for estimating the actual fish benefits of alternative bypass
            actions because FISHPASSranks the alternatives according to estimated
            benefits.

             (ii) The whole point of using FISHPASSis to attempt to have the model
             rank alternatives, not make the decision.

             (iii) FISHPASSis a deterministic model; specific points, rather than ranges,
             are used in the model. A probabilistic model should be used, but there is
             none currently available to do this.

             GAO Observation: (i) According to University of Washington researchers,
             FISHPASS,as used by the Corps to evaluate bypass improvements, was the
             best available analytical tool at the time. As such, using the model to



             Page 4 1                                   GAO/RcEDBO-180   Columbia   River Basin Fish Bypasses
            Appendix I
            Consolidation   of Fish and Wildlife Agencies’,
            lndlan Tribes’, and the Council’s Concerns;
            Corps’ Responses; And GAO’s Observations




            rank alternatives based on relative survival estimates was an appro-
            priate way to analyze its results. However, we agree that FISHPASSdoes
            not estimate the “actual fish benefits” of bypass actions. Rather, the
            ranking of model results only suggests which alternatives might be
            better or worse than others. The estimated fish benefits cannot be inter-
            preted as exact.

            (ii) While the Corps’ response states that the whole point of using
            FISHPASSwas to rank alternatives and not make the decision, that
            appears to have been how the Corps’ decision makers used the modeling
            results-to justify its decision not to recommend bypasses at The Dalles
            and Ice Harbor Dams for further federal funding. FISHPASSresults alone
            are insufficient support for the decision not to pursue bypasses at these
            two locations,

            (iii) Both using “point estimates” for parameters in a deterministic mod-
            eling approach or “ranges” for parameter values in a probabilistic mod-
            eling approach have merit. More important, however, the Corps did not
            indicate how reliable, or close to reality, the results were from the
            method it chose to use. The Corps performed sensitivity analysis, but
            that type of analysis cannot determine the reliability of a model.

Conaxn 6c   The Corps’ method for calculating system survival estimates has not
            been agreed to by the fishery agencies and Indian tribes.

            Corps Response: The statement is true.

            GAO Observation: The Corps is not required to obtain agreement on a
            method for calculating system survival estimates. However, doing so
            would have helped to resolve the bypass controversy.

Concern6d   Analysis does not include noneconomic factors or regional economic
            multiplier effects. Noneconomic factors would include (1) Indian treaty
            fishing rights; (2) U.S./Canada Pacific Salmon Treaty; and (3) Indians’
            ceremonial, cultural, and religious significance of salmon and steelhead
            trout. Regional effects include the economic development and quality-of-
            life benefits of maintaining healthy fisheries.

            Corps Response: The Goals Report does mention that these noneconomic
            factors should be considered in any decision on whether or not the
            bypasses should be constructed. They were not included in the economic
            analysis because there was no reliable way to place a value on them.



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            Appendix I
            Consolidation      of Fish and Wildlife Agencies’,
            Indian Tribes’, and the Council’s Concerns;
            Ch’ps’  lhsp~nses;     And GAO’s Observations




            GAO Observation: The Corps’ analysis does not include noneconomic fac-
            tors. Corps engineering regulations require that project analysis identify
            and, to the fullest extent practicable, take into consideration
            noneconomic factors, such as environmental effects. The Goals Report
            analysis ignored noneconomic considerations because, according to
            Corps officials, the Division was directed by headquarters to perform an
            analysis that was limited to economic considerations.

            GAO believes the Corps could have done more to consider noneconomic
            values in its analysis, even if attaching a dollar value to all noneconomic
            effects was not feasible. For example, the estimate of project effects
            could have focused on particular fish stocks where nor-monetary values
            might be quite high.

Concern6e   The Corps’ analysis does not incorporate the real benefits of increased
            juvenile survival. A life-cycle analysis would show that small improve-
             ments in juvenile survival can result in substantial increases in run sizes
             over time. For example, a constant 3.5 percent increase in survival could
             result in doubling the population in 20 years. The model incorrectly
             assumes a constant production population of all stocks of salmon and
             steelhead for all studies and water conditions.

            Corps Response: The FISHPASSmodel used in the Goals Report had
            assumed doubling the run had already occurred and the population was
            stable so life-cycle modeling would have been appropriate.

            The model is very optimistic on the issue of whether the population of
            all stocks of salmon and steelhead will remain constant, This assumption
            yields the highest possible benefits for the bypasses because a large
            number of fish are assumed to arrive at each project.

            The fishery agency and tribe concept of life-cycle modeling for bypass
            alternatives assumes that the fish populations are affected only by the
            Corps’ dams. This is untrue; the effects of other factors are much
            greater. The impact of ocean survival and production (hatchery
            capacity) make life-cycle modeling largely useless in determining the
            effects of the dams.

            GAO Observation: FISHPASSis not a full life-cycle model. FISHPASSsimulates
             one generation from the time juvenile fish migrate downstream to when
             adults are harvested. A life-cycle model ideally would provide more
             information about longer term effects on the fish population. However,



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            Appendix I
            Gmsolidation        of Fish and Wildlife
                                             Agencies’,
            Indian   Tribes’,             Concerns;
                                and the Council’s
            Corps’ Responses; And GAO’s Observations




            more research and data are needed to produce a reliable life-cycle
            model.

            FISHPASS(as used in the Goals Report) assumed a fish population for
            1995 based on completion of the Corps’ Lower Snake River Compensa-
            tion Plan and state and regional initiatives, regardless of decisions made
            by the Corps on bypasses. Based on estimates from the fish agencies, the
            Corps assumed there would be more than a doubling of the 1987 number
            of natural and hatchery fish migrating downstream in 1995 (56 million
            in 1987 and 130 million in 1995).

Concern6f   The Corps’ analysis considers only total numbers of fish rather than
            individual stocks of fish, such as natural stocks entering the Snake or
            Columbia Rivers below transportation collection points. BPA has identi-
            fied at least four natural stocks of fish that could be significantly
            affected. In addition, a disproportionate number of fish not collected
            and transported are wild or natural smolts which migrate before and
            after the bulk of hatchery migrants. Lastly, the importance of genetic
            diversity is not included.

            Corps Response: The total number of fish at specific collection points is
            considered in the model. The impact on individual stocks could be con-
            sidered in future models. Transportation in the model does not affect
            wild or natural juvenile fish any differently than hatchery juveniles.

            GAO Observation: The Corps’ analysis does not study individual stocks or
            the importance of genetic diversity. As used by the Corps, FISHPASScon-
            siders spring and fall chinook, salmon, and steelhead trout. Including
            stocks in addition to species would be a more accurate way of reflecting
            the fish population status because it could show adverse effects on indi-
            vidual stocks of fish.

Concern6g   The Corps’ analysis assumes a homogeneity of fish stocks that does not
            exist. No value is placed on fish necessary for reproduction, especially
            those necessary for rebuilding depleted stocks.

            Corps Response: The Corps assumed stocks were already at a stable
            level.

            GAO Observation: By not distinguishing  among fish stocks, the Corps’
            analysis values them equally. Also, the Corps’ analysis does not place a
            value on fish necessary for reproduction or for rebuilding depleted
            stocks.


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            Appendix I
            Consolidation   of Fish and Wildlife Agencies’,
            IndIan Tribes’, and the Council’s Concerns;
            Corps’ Responses; And GAO’s Observations




Concern6h   The model ignores the cumulative effect of turbine passage by several
            dams on survival and assumes that turbine and reservoir mortality are
            independent. Mortality resulting from increased susceptibility to disease
            or increased vulnerability to predators caused by injury or stress from
            turbine passage through one dam or a series of dams is considered reser-
            voir mortality in FISHPASS,not turbine mortality.

            Corps Response: FISHPASSis a system model; it looks at survival of fish
            entering above the Corps’ complex of dams and tracks survival to below
            Bonneville Dam. These numbers are then converted to adult returns for
            economic purposes. FISHPASSdoes assume that the chance of survival
            remains unchanged as the fish migrate through the system. For
            example, a fish safely passing through a turbine or spillway is assumed
            to have the same probability of surviving through the next dam. At least
            one study has found that fish surviving through a turbine have the
            same chance of returning to spawn as fish that were bypassed. There
            may be a long-term effect on fish passing through spill over a dam, but
            the Corps is unaware of any data on this.

            GAO Observation: FISHPASSdoes not account for possible cumulative
            debilitating effects on fish health such as injury, descaling, or stress
            from passing by several dams. However, as the Corps stated, we are not
            aware of any data on this.

Concern6i   The number of projected fish used in the model for 1987 and 1995 is not
            accurate. For example, the model used 5.5 million steelhead for 1987.
            However, according to juvenile monitoring statistics, 9.47 million
            hatchery steelhead were released in 1987, including several million more
            natural steelhead.

            Corps Response: The numbers refer to the Dalles Report; all of the num-
            bers used in this report have been revised.

            GAO Observation: An appendix to The Dalles Report incorporated
            revised estimates of the number of juvenile fish projected to be in the
            river. We did not evaluate the accuracy of these estimates. While the
            numbers of hatchery fish are predictable, data on natural and wild juve-
            nile fish are less certain.

Concern6j    The 30- to 40-percent cumulative reservoir mortality estimate for juve-
             nile fish is unsupported by research data. At the very least, a sensitivity
             analysis using a reasonable range of reservoir mortality estimates



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            Appendix I
            Consolidation  of Fish and Wildlife Agencies’,
            Indhn Tribes’, and the Council’s Concerns;
            Corps’ Responses; And GAO’s Observations




            should be conducted and model output should be a range, not point
            estimates,

            Corps Response: Reservoir mortalities estimates generated by FISHPASS
            were based on existing research. They are a function of water flow (rep-
            resenting the speed at which fish travel through a reservoir) and dis-
            tance (how far fish have to travel per reservoir). The weaker the flow,
            or the larger the reservoir, the more fish are estimated to die. Reservoir
            mortalities also differ by species or age of fish.

            The 30- to 40percent cumulative reservoir mortality is a conservative
            estimate mentioned in the Goals Report to roughly illustrate the extent
            of reservoir mortality. In a sensitivity analysis of bypass options using
            FISHPASS,reservoir mortalities varied greatly per reservoir and in total
            depending on the different conditions assumed. In FISHPASS,the calcula-
            tions are based on the best available research.

            GAO  Observation: The draft report from the University of Washington’s
            review of FISHPASSindicates that the model’s predictions are very sensi-
            tive to reservoir survival conditions and that such predictions would be
            “most improved” by more study of this parameter.

            Predation has been identified as a major cause of fish mortality in the
            John Day reservoir. Predator fish at John Day reservoir are estimated to
            kill 7 to 61 percent of juvenile salmon and steelhead trout that enter the
            reservoir. According to a Corps official, the best data on reservoir mor-
            tality and predation are from the John Day study. Mortality rates and
            predation at places other than John Day reservoir have not been tested
            to the same extent.

Concern6k   Fish guidance efficiency values are in some cases undocumented and
            appear overly optimistic, especially with the use of gate raises and low-
            ered submersible traveling screens. For example, at Lower Granite Dam,
            yearling fish guidance efficiency increases from 53 to 77 percent (a 45
            percent increase) via gate raises alone, and then to 88 percent from
            extending submersible traveling screens. The group with this concern
            was unaware of research to support this level.

            Corps Response: Because of a lack of data with regard to fish guidance
            efficiencies at some dams for some species-expressed as a percent of
            fish passing by a dam which are guided into the collection channel of its
            bypass system-judgment     is involved in using any numbers for analyt-
            ical purposes. The Corps had to use a point estimate because FISHP~ZSSis


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            Appendix I
            Consolidation   of Fish and Wildlife Agencies’,
            Indian Tribes’, and the Council’s Concerns;
            Corps’ Responses; And GAO’s Observations




            a deterministic model. The research data show a range for fish guidance
            efficiency; the Corps had to pick the most likely point that it believed
            representative.

            GAO Observation: We did not evaluate the accuracy of fish guidance effi-
            ciencies Research to test the fish guidance efficiencies of extended trav-
            eling-screen bypasses, where the screens are 40 feet long rather than the
            standard 20 feet, have been based on prototypes rather than actual
            installation. Therefore, the high fish guidance efficiencies for this type
            of screen are estimates.

Concern61   (i) The Corps’ Goals Report stresses the benefit and value of using the
            ice and trash sluiceways at Ice Harbor, The Dalles, and Bonneville Dams.
            However, it fails to present the wide range in the data gathered from
            sluiceway effectiveness studies, nor does it state that point estimates
            made from hydroacoustics studies are lacking error bounds. Further, the
            fishery agencies and tribes have repeatedly disputed the Corps’ choice
            of the highest value for sluiceway effectiveness at Ice Harbor.

            (ii) Existing long-term spill agreement levels were not included. Spill is
            needed in the interim, until bypass systems are installed, to achieve
            comparable levels of survival for all migrating juvenile salmon and
            steelheads. Including the cost savings from not having to spill would
            increase the benefit-to-cost ratio up to 1.46 for Ice Harbor and 1.04 for
            The Dalles, using willingness-to-pay economic values. However, using
            willingness-to-sell values would increase the benefit-to-cost ratios to 2.4
            for Ice Harbor and 1.4 for The Dalles Dam.

            Corps Response: (i) The 40- to 50-percent sluiceway efficiencies in the
            model are based on the best available data.

            (ii) The statement that existing long-term spill agreement levels were not
            included in the model parameters is true. The spill agreement was not in
            place when the Corps prepared the Goals Report. Further, the Corps has
            consistently stated that spill is so cost-ineffective that it is not reason-
            able to use spill to justify bypass construction.

            GAO Observation: (i) The Corps used the Mainstem Passage Advisory
            Committee sluiceway estimates of 51 percent at Ice Harbor and 40 per-
            cent at The Dalles for analyzing bypass alternatives with FISHPASS.How-
            ever, the Chairman, Mainstem Passage Advisory Committee, said these
            numbers were controversial estimates. He indicated that research shows
            sluiceway efficiency can range from 30 to 70 percent.


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             Consolidation   of Fish and Wiidlife Agencies’,
             Indian Tribes’, and the CounciI’s Concerns;
             Corps’ Responses; And GAO’s Observations




             (ii) At GAO'S request, the Corps incorporated spill into the benefit and
             cost analysis. By changing this assumption, the analysis showed the ben-
             efits of submerged traveling-screen bypass facilities at The Dalles and
             Ice Harbor Dams would exceed the costs when spill was included.

Concern 6m   Point estimates for turbine survival in the Goals Report are not
             documented.

             Corps Response: The turbine survival figures were jointly agreed to by
             the region through the Mainstem Passage Committee of the Council.

             GAO Observation: The Goals Report does not document point estimates
             for turbine survival used in FISHPASS.The Corps has stated that FISHPASS
             assumes that 85 percent of fish going through a turbine survive.
             According to one of the researchers, preliminary results from the Uni-
             versity of Washington review of the model confirm the survival esti-
             mate, and conclude that it is reasonable given the evaluation of existing
             research. The Corps’ estimate is the same as the Mainstem Passage
             Advisory Committee’s However, the Chairman of the committee said
             there was no regional agreement on the estimates.

             As discussed in chapter 3, only two studies have been conducted com-
             paring, at the same dam, the survival of fish using the bypass with
             other routes to get by the dam. The ongoing study at Bonneville’s second
             powerhouse has shown that more fish survive going through the tur-
             bines than through the bypass system.

Concern6n     The high 97.6 percent dam passage survival estimate without any spill
              at McNary Dam used in FISHPASSshould be justified.

              Corps Response: Dam passage survival represents the percent of fish
              surviving all the possible routes by a dam: through the turbine, the
              bypass system, the sluiceway, or over the spillway. Given all the pos-
              sible ways of surviving passage at McNary Dam, the Corps believes that
              97.6 percent is possible.

              GAO Observation: The McNary Dam passage survival of 97.6 percent,
              assuming no spill, is an estimate. The estimate might be more likely
              assuming spill. Additional research is needed to know what the actual
              dam passage survival is with extended submersible travel screens
              because none have been permanently installed.




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             Appendix        I
             Consolidation   of Fish and Wildlife Agencies’,
             Indh   Tribes’, and the Council’s Concerns;
             Corps’ Responses; And GAO’s Observations




Concern 6o   The assumptions used in the FISHPASSmodel are not clearly stated. For
             example, escapement levels or harvest rates are not documented. This
             biological information is critical to a credible biological evaluation.

             Corps Response: All of the assumptions of FISHPASSmay not be clearly
             stated in the Goals and Dalles Reports. However, a FISHPASSUser Manual
             does describe these assumptions.

             GAO Observation: The assumptions used in the model are not all clearly
             stated in the Corps’ reports and sometimes not even in the FISHPASSUser
             Manual (1988). The User Manual, however, does document the FISHPASS
             assumptions about the levels of escapement (the number of returning
             adult fish that are allowed to remain free for spawning purposes) and
             harvest (the number of returning adult fish that are caught for commer-
             cial or sport purposes).

             The model assumes set escapement levels for the three types of fish con-
             sidered in Frsm=@s-spring chinook, fall chinook, and steelhead trout.
             Harvest levels, on the other hand, were variable. The Corps assumed
             50,100 spring chinook, 71,900 fall chinook, and 174,300 steelhead would
             have to escape for spawning each year. Harvest levels were then calcu-
             lated as the number of returning fish above and beyond these amounts.

Concern6p    Transport benefit ratios for transported versus nontransported spring
             chinook of 4.5 to 1 from the two Snake River collection points should be
             closer to 2 to 1. (The transport benefit ratio is probably even lower from
             McNary Dam.) Also, an analysis by the Columbia Fish and Wildlife
             Authority indicates that significant mortality is occurring after release
             from the barges.

             Corps Response: Transport benefit ratios as stated in the concern were
             not used in FISHPASS.The Corps represented survival differences for
             transported versus nontransported fish in another way because of how
             the model calculates survival.

             Research by the National Marine Fisheries Service shows a low level of
             fish mortality after release from transport barges. F’ISHPASSincludes this
             in its calculations of adult fish returning from the ocean.

             GAO Observation: We did not evaluate how FISHPASStransportation                         mor-
             tality calculations compare to statistics on transport benefit ratios.




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                ckwwolidation   of Fish and WlldIife Agencies’,
                Indian Tribes’, and the Council’s Concerns;
                Corps’ Responses; And GAO’s Observations




Concern6q       Improved survival may not result for transported fish from John Day
                Dam as proposed.

                Corps Response: Studies would be needed to prove this one way or the
                other. The Corps has proposed research on transport from John Day
                Dam but it has not been supported by fish agencies.

                GAO Observation: Since the Corps, as of May 1990, does not transport
                fish from John Day Dam, research would be needed to show the effects
                of transportation from this location.

Concern6r       Transportation will not meet the same biological objectives as the instal-
                lation of mechanical bypass screens. For example, until further research
                can be concluded and agreement on benefits achieved, transportation of
                spring and summer chinook salmon should be undertaken only as called
                for by the region’s fish and wildlife agencies and Indian tribes. Regional
                fisheries biologists have four principal concerns with transportation of
                spring and summer chinook. They are

            l homing impairment and straying problems;
            . cumulative stressful conditions encountered at collection facilities;
            . increased exposure to diseases in barges, trucks, and collection facilities;
              or
            l potential for accidents involving large fish kills in transportation
              program.

                Corps Response: The problem with spring chinook may be bacterial
                kidney disease. Research is currently ongoing to address this issue. If
                this hypothesis is correct, it can readily be argued that additional
                bypass systems would provide little benefit to these fish. With the dis-
                ease, these fish do not survive acclimation to seawater whether they are
                transported or migrate in-river. Bypass systems do not correct this
                problem.

                Transportation         of spring and summer chinook is being included in the
                FISHPASSanalysis because it represents what is actually happening at
                those projects.

                GAO Observation: As agreed with the fish and wildlife  agencies and
                Indian tribes, the Corps does not transport spring chinook in average
                and greater-than-average water flow years. Also, research by t,he
                National Marine Fisheries Service has indicated that fall chinook and
                steelhead benefit from transportation, but spring and summer chinook


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            Cmsolidation        of Fish and WiIdIIfe
                                             Agencies’,
            Indian   Tribes’,             Concerns;
                                and the Council’s
            Corps’ Responses; And GAO’s Observations




            do not transport well. On the other hand, researchers at the University
            of Washington in their draft report on FISHPASSsuggest that all study
            results on transportation are “questionable.”

Concern6s   The Corps’ preferred alternative (maximum juvenile transportation)
            understates and excludes costs. Total capital costs of $5 million should
            be $28 million (levelized to $2.5 million annually at 8.875 percent) and
            annual operations and maintenance costs should be $1.8 million. Adding
            the levelized annual capital cost to the annual operations and mainte-
            nance cost gives a total annual cost of about $4.3 million.

            Corps Response: The incremental costs for transportation                    and bypass
            were included on a yearly basis.

            GAO Observation: We did not evaluate transportation     costs. Therefore,
            we have no basis on which to make an observation about the accuracy
            of the “total annual cost” for transportation, However, in an incre-
            mental analysis, total annual costs would include new but not previous
            expenditures, such as the costs of existing transportation barges and
            facilities.

Concern6t   The draft Dalles Report underestimates the fishery benefits derived
            from a fish collection-bypass facility at The Dalles Darn. The number of
            fish arriving at the project was based on a projection of fish production
            for 1992. The Northwest Power Planning Council has estimated that 5 to
            11 million salmon and steelhead were lost due to hydropower develop-
            ment and operation. A tripling of current production would be required
            to achieve mitigation at the low end of this range and much of this pro-
            duction would not occur until after 1992. The Council has set an interim
            goal of doubling the existing salmon and steelhead runs. The benefit-to-
            cost ratio analysis is very sensitive to the number of fish arriving at the
            project and should use an estimate of fish arriving at the project when
            full mitigation is achieved. Higher production levels would increase
            fishery benefits from the collection-bypass system.

             Corps Response: The numbers used in The Dalles Report were revised to
             represent 1995 expected numbers, This represents the 5 million fish
             interim goal set by the Council.

             GAO Observation: We disagree with the Corps’ response. The Dalles
             Report shows that the Corps based its recommendations on an analysis
             assuming 1992 rather than 1995 conditions. In the report, the Corps’
             benefit and cost analysis is sensitive to the number of juvenile fish


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            Appendix I
            Consolidation       of Fish and Wlldllfe
                                               Agencies’,
            Indian   Tribes’,               Concerns;
                                and the Council’s
            Corps    Responses; And GAO’s Observations




            assumed to be in the river. Increasing the number of fish would alter
            overall benefits. According to a Corps official, had 1995 rather than
            1992 conditions been assumed, more fish would have been projected to
            be in the system. As demonstrated in an appendix to the report using
            1995 conditions and the no-head-loss assumption, the benefits would
            have exceeded the costs for a bypass at The Dalles Dam under partial
            transportation conditions. On that basis, the Corps could have recom-
            mended construction of a bypass at The Dalles Dam.

            As previously stated, we did not evaluate the accuracy of estimates of
            juvenile fish projected to be in the river. While the numbers of hatchery
             fish are predictable, data on natural and wild juvenile fish are less
            certain.

Concern6u   The Corps’ economic analysis incorrectly “assumes that the value of
            Indian tribal fisheries is the same as sport fisheries.”

            Corps Response: The model does assume that the value of Indian tribal
            fish is the same as sport and commercial fish. A report prepared for the
            Rock Island Project, of Chelan Public Utility District, says that tribal
            fish is best valued as a commercial fishery because this is basically what
            the Indians do-sell the fish.

            GAO Observation: Indian tribes maintain that fish have more than just
             commercial value. According to the Director of the Columbia River
             Intertribal Fish Commission, this additional value or benefit to Indian
             tribes would be noneconomic. The value chosen for Indian tribal fish
             demonstrates how the Corps did not consider noneconomic benefits.

Concern6v    The Corps uses a “willingness to pay” value for determining the benefit
             of harvestable adult fish. However, under Corps criteria, they should
             have used a “willingness to sell” value, which would economically jus-
             tify bypass facilities at John Day and The Dalles.

             Corps Response: Corps engineering regulations allow for using a “will-
             ingness to pay” rather than a willingness to sell value for fish. Corps
             policy and guidelines for National Economic Development evaluation
             require that if actions are considered restorative or mitigative, then a
             willingness to sell value should be used to determine the benefits. How-
             ever, the policy and guidelines also state that for cases when there is no
             reliable empirical method for estimating willingness to sell (also referred
             to as “willingness to accept compensation for losses”), then a willingness
             to pay value should be used.


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Appendix I
Consolidation   of Fish and WlldIife Agencies’,
Indian Tribes’, and the Council’s Concerns;
Corps’ Responses; And GAO’s Observations




GAO Observation: The applicable Corps engineering regulation, ER 1105-
2-40, Economic and Environmental Principles and Guidelines for Water
and Related Land Resources Implementation Studies, Change 2, July 9,
1983, states that using a “willingness to pay” value was permissible.




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Appendix II                                                                                      .-
Major Contributors to This Report


                          Judy England-Joseph, Associate Director, Energy Issues
Resources,                Charles M. Adams, Assistant Director
Community, and            David G. Wood, Assistant Director
                          Molly MacLeod, Reports Analyst
Economic
Development Division,
Washington, DC.

                          William E. Hanson, Evaluator-in-Charge
Seattle Regional Office   Dianne L. Whitman, Staff Evaluator
                          Laurie M. Jones, Staff Evaluator
                          Stanley G. Stenersen, Reports Analyst



Consulting Economist




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