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 Limitations in Benefit Analysis and Regional ’ 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 Chapter 2 Ldmitatlonc~ ln Benefit Analysis and Regional Involvement Raise Questions About Corps Bypam Decisions 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). Page 18 GAO/BcEDQ@18O Cdnmbti River Basin Flab Bypawea 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. Page 19 GAO/RCED9O-190 Columbia River Basin Fish Bypasses Chapter 2 Limitstions in Benefit Analysis and Regional involvement Rak Questione About Corps Bypass Decisions -- 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. Page 20 GAO/RCED-g@l&I Columbia River Basin Fish Bypasses Chapter 2 Limitations in Benefit Analysis and Regional Involvement Raise Questions About Corps Bypass Decisions 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. Page 2 1 GAO/RCEDtWl80 Columbia River Basin Fish Bypasses Chapter 2 Limitations in Benefit Analysie and Regional Involvement Raise Que~~tious About Corpe Bypass Decisions 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; Page 22 GAO/RCEDB&lBo Columbia River Basin Flsb Bypaws 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 Chapter 2 Limitations in Benefit Analysis and Regional Involvement Raise Questions About Corps By-pass Decisions 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. Page 24 GAO/RCEXMO-180 Columbia River Basin Fish Bypasses Chapter 2 Limitations ln Beneflt Analysis and Regional Involvement Raise Questions About Corps Bypass Decisions 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. Page 25 GAO/RC~WlSO Colnmbti River Basin Fish Bypawes Chapter 2 Umit.ations in Benefit Analysis and Regional Involvement Raise Questions About Corps Bypass De&ions 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. Page 26 GAO/RCED!W180 Columbia River Basin Fish Bypasses Chapter 2 Limitations in Benefit Analysis and Regional Involvement Raise Qwstions About Corps Bypass Decisions 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 Page 40 GAO/RCEDsOl80 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 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. Page 42 GAO/EKED-9@180 Columbia River Basin Fish Bypasses 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, Page 43 GAO/RCED-90-180 Columbii River Basin Fish Bypasses 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. Page 44 GAO/RCELMJ180 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 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 Page 45 GAO/RCED9@180 Columbia River Rasin Fish Bypasses 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 Page 46 GAO/RCEJMO-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 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. Page 47 GAO/RCEDM-180 Columbia River Basin Fish Bypasses Appendix I 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. Page 48 GAO/RCED-W-180 Cohunbia River Basin Fish Bypasses 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. Page 49 GAO/RCED-90-180 C&unb& River Basin Fish Bypasses Appendix I 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 Page 60 GAO/RCED-90-180 Columbia River Basin Fish Bypasses Appendix I 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 Page 61 GAO/RCED-W180 CoIumbIa River Basin Fish Bypasses -- 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. Page 62 GAO/RCED-SO-180 Columbia River Basin Fiih Bypasses 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. Page 53 GAO/RCEIMO-180 C&unbla River Basin Fish Bypasses 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 (005393) Page 64 GAO/RCEDW160 Columbia River Basin Fish Bypasses
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)