Oregon Inlet Jetty Project
Environmental and Economic Concerns Need to Be Resolved Gao ID: GAO-02-803 September 30, 2002Oregon Inlet is the primary route to the ocean for hundreds of commercial and recreational fishing vessels operating in the Outer Banks region of North Carolina. However, the inlet experiences more high winds, strong tides, and shifting sand than any other inlet on the coast of the United States. This high-energy environment often creates sand bars and large breaking waves at the inlet's entrance to the ocean, commonly known as the ocean bar. These conditions, especially when combined with the severe storms that frequent the area, can swamp a boat or run it aground, imperiling both life and property. During the past 19 years, the Army Corps of Engineers has had difficulty maintaining the ocean bar navigation channel at Oregon Inlet at its authorized 14-foot depth. Specifically, from 1983 through 1994, the Corps spent on average $4.1 million per year dredging the channel, but was only able to maintain the authorized 14-foot depth on average 23 percent of the time. After 1994, the Corps spent an average of $2 million per year, but the percentage of time the channel depth was maintained at its authorized depth declined to 15 percent. The Corps' most recent economic analysis of the proposed Oregon Inlet jetty project, issued in 2001, has several limitations, and as a result, does not provide a reliable basis for deciding whether to proceed with the project. Of the eight completed jetty projects constructed similarly to the proposed Oregon Inlet jetty project, two are generally performing as planned. Of the six other similar projects, three have required more dredging and higher maintenance costs than expected, and two have had their weirs closed. In designing the proposed Oregon Inlet jetty project, the Corps' Wilmington District Office applied lessons learned from the construction of similar jetty projects and from internal Corps guidance. Both the Department of Commerce and the Department of the Interior support the goal of providing a safe navigation channel through Oregon Inlet for commercial and recreational fishing vessels. However, both departments support a dredging-only approach to achieve that goal in an environmentally acceptable manner.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-02-803, Oregon Inlet Jetty Project: Environmental and Economic Concerns Need to Be Resolved
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Report to Congressional Requesters:
September 2002:
OREGON INLET JETTY PROJECT:
Environmental and Economic Concerns Still Need to Be Resolved:
GAO-02-803:
Results in Brief:
Background:
Corps Generally Has Not Maintained the Oregon Inlet Ocean Bar
Navigation Channel at Its Authorized Depth:
Corps‘ Economic Analysis for the Proposed Oregon Inlet Jetty Project
Has Several Limitations That Undermine Its
Usefulness:
Performance of Similar Jetty Projects Has Been Mixed:
Corps Applied Lessons Learned from Similar Jetty Projects in Designing
the Oregon Inlet Jetty Project, but Information on Fish Larvae
Migration Is Not Available:
Commerce and Interior Remain Concerned That the Oregon Inlet Jetty
Project Will Harm the Environment:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Scope and Methodology:
Appendixes:
Appendix I: The Corps‘ Process for Developing Water Resource Projects:
Appendix II: Chronology of Significant Events for the Oregon Inlet
Jetty
Project, 1950 through 2002:
Appendix III: Approved Oregon Inlet Dredging Operations that Were Not
Performed:
Appendix IV: Review of the Corps‘ Economic Analysis of the Proposed
Oregon
Inlet Jetty Project:
Appendix V: Comparison of the Proposed Oregon Inlet Jetty Projects:
Appendix VI: Comments from the Department of the Army:
Appendix VII: Comments from the Department of the Interior:
Appendix VIII: Comments from the Department of Commerce:
Appendix IX: GAO Contact and Staff Acknowledgements:
Tables:
Table 1: Estimated Average Number of Annual Trips Made by Commercial
Fishing Vessels through Oregon Inlet, for the Periods 1984-1986 and
1999-2001:
Table 2: Performance of the Eight Jetty Projects Incorporating Weirs:
Table 3: Approved Oregon Inlet Dredging Operations That Were Not
Performed for Some of the Fiscal Years from 1990 through 2001:
Table 4: Comparison of Estimated Annual Benefits and Costs of
Alternatives for Achieving a 20-Foot-Deep Navigation Channel for Oregon
Inlet:
Table 5: Summary of Information in U.S. Coast Guard Investigation Files
on Vessel Losses at Oregon Inlet, 1961 through 1986:
Table 6: Listing of Vessel Losses and Deaths Attributed to Conditions
at
Oregon Inlet, June 28, 1986, through November 27, 2001:
Table 7: Listing of Vessel Damages Attributed to Conditions at Oregon
Inlet between June 28, 1986, and September 30, 2001:
Table 8: Key Characteristics of the Proposed Oregon Inlet Jetty Project
and Similar Completed Jetty Projects:
Figures:
Figure 1: Oregon Inlet‘s Location Along the North Carolina and Virginia
Coastlines:
Figure 2: Aerial View of Oregon Inlet on September 18, 2001:
Figure 3: The Corps‘ Proposed Design for the Oregon Inlet Jetty Project
as of September 2001:
Figure 4: Funding Requested, Approved, and Expended for Dredging the
Oregon Inlet Ocean Bar Navigation Channel, Fiscal Years 1990 through
2001:
Figure 5: The Weir in the North Jetty at Masonboro Inlet, North
Carolina:
Figure 6: The Dual Jetty Project at Colorado River Inlet, Texas:
Abbreviations:
CEQ Council on Environmental Quality:
DOI Department of the Interior:
EIS Environmental Impact Statement:
FWS Fish and Wildlife Service:
GAO General Accounting Office:
GDM General Design Memorandum:
NMFS National Marine Fisheries Service:
NOAA National Oceanographic and Atmospheric Administration:
NPS National Park Service:
OMB Office of Management and Budget:
September 30, 2002:
The Honorable Max Baucus
United States Senate:
The Honorable John Edwards
United States Senate:
Oregon Inlet is the primary route to the ocean for hundreds of
commercial and recreational fishing vessels operating in the Outer
Banks region of North Carolina. However, the inlet experiences more
high winds, strong tides, and shifting sand than any other inlet on the
Atlantic coast of the United States. This high-energy environment often
creates sand bars and large breaking waves at the inlet‘s entrance to
the ocean, commonly known as the ocean bar. These conditions,
especially when combined with the severe storms that frequent the area,
can swamp a boat or run it aground, imperiling both life and property.
According to the U.S. Army Corps of Engineers and U.S. Coast Guard
data, over the 40-year period 1961 through 2001, hazardous conditions
in the inlet were a factor in 25 deaths and the loss of 22 vessels.
In 1950, in an attempt to improve navigation at Oregon Inlet, the
Congress authorized the Corps to dredge a channel in the inlet--called
the ocean bar navigation channel--to a depth of 14 feet.[Footnote 1]
From 1960 through 2001, the Corps‘ Wilmington District Office, which is
responsible for maintaining the ocean bar navigation channel at Oregon
Inlet, spent about $108 million dredging this channel.[Footnote 2]
Additional efforts to improve the safety of the channel are conducted
by the U.S. Coast Guard, which is responsible for, among other things,
maintaining the navigation aids that help guide vessels through the
inlet. In 1970, in an effort to stabilize Oregon Inlet and in response
to local concerns that a deeper channel was needed to accommodate
fishing vessels and commercial traffic, the Congress authorized the
construction of dual rock jetties and a 20-foot-deep ocean bar
navigation channel for Oregon Inlet.[Footnote 3] Since this
authorization, the Corps has completed and updated numerous economic
and environmental analyses to determine if construction of the project
is justified. In the latest update of its economic analysis, completed
in 2001, the Corps estimated that the project would yield annualized
net benefits of about $7.2 million over 50 years, largely from savings
that were projected to be attained from reduced operating costs for
commercial fishing vessels and increased activity by recreational
boaters. Annualized costs were estimated at about $4.5 million. As a
result, annual net benefits (benefits minus costs) for the proposed
jetty project were estimated at $2.7 million. However, although the
Corps and others have completed many studies over the last 30 years,
the Congress has never appropriated funds specifically to construct the
project. During this period there have been major disagreements among
federal, state, and local governmental entities, including the
Departments of Commerce and Interior, as well as among environmental,
fishing, and recreational groups, about whether the project is
economically justified and whether it would harm the environment by,
among other things, increasing beach erosion and restricting the
migration of fish larvae from the ocean to the sounds inside the inlet,
where the larvae develop into fish.
You asked us to review several issues related to the Corps‘ Oregon
Inlet jetty project. Specifically, we agreed to (1) assess federal
efforts to maintain the ocean bar navigation channel in Oregon Inlet,
(2) assess the extent to which the Corps‘ 2001 economic analysis of the
jetty project is useful for decision making, (3) provide information on
the performance of similar jetty projects, that is, those constructed
with dual jetties and a low section called a weir,[Footnote 4] (4)
determine whether the Corps‘ Wilmington District Office applied lessons
learned from similar jetty projects in its design of the Oregon Inlet
jetty project, and (5) identify and discuss concerns raised by the
Departments of Commerce and Interior about development of the jetty
project.
Results in Brief:
During the past 19 years, the Corps has had difficulty maintaining the
ocean bar navigation channel at Oregon Inlet at its authorized 14-foot
depth. Specifically, from 1983 through 1994, the Corps spent on average
about $4.1 million per year dredging the channel, but was only able to
maintain the authorized 14-foot depth on average about 23 percent of
the time. After 1994, the Corps spent an average of about $2 million
per year, but the percentage of time the channel depth was maintained
at its authorized depth declined to about 15 percent. According to a
2001 engineering and design document issued by the Corps, its dredging
efforts at Oregon Inlet have not provided a safe and navigable ocean
bar navigation channel, and hazardous navigation conditions at the
inlet will continue to cause the loss of human life and injuries as
well as vessel losses and damages. Wilmington District Office officials
said that the high-energy environment and storms associated with Oregon
Inlet have often thwarted the Corps‘ plans and depleted its funding for
dredging the inlet. In addition, the district has sometimes had to
reallocate funds that were earmarked for dredging Oregon Inlet to other
district projects in response to emergencies caused by the frequency
and magnitude of area storms. Further, because of the Corps‘ limited
dredging and the inlets high-energy environment, the Coast Guard has
been unable to maintain and properly position its navigation buoys for
the channel, which further increases the risk of damage to vessels and
injuries to people.
The Corps‘ most recent economic analysis of the proposed Oregon Inlet
jetty project, issued in 2001, has several limitations, and as a
result, does not provide a reliable basis for deciding whether to
proceed with the project. For example, the Corps relied on outdated
data to estimate the benefits to large commercial fishing vessels
(trawlers). More recent data indicates that trawlers currently use the
inlet far less than the Corps estimated in its economic analysis. On
the other hand, the Corps did not analyze the potential benefits the
proposed jetty project may provide to smaller commercial fishing
vessels. However, because these smaller vessels have shallower drafts
than trawlers, the extent to which they might benefit from the jetty
project is uncertain. The analysis also did not account for the
economic value of the lives that might be saved by the jetty project,
which could understate benefits; it also overstated the cost of the
current dredging program, and it used an overly optimistic assumption
concerning future dredging needs that would tend to understate the cost
of the jetty project. We did not assess the net effects of all the
limitations we found with the economic analysis because obtaining the
necessary data would require an inordinate amount of time and expense.
These limitations, however, can result in either overstated or
understated estimated benefits and costs.
Of the eight completed jetty projects constructed similarly to the
proposed Oregon Inlet jetty project, two are generally performing as
planned. Of the six other similar projects, three have required more
dredging and higher maintenance costs than expected, and two have had
their weirs closed--one because the responsible Corps‘ District did not
accurately determine the direction of sand movement and constructed the
weir on the wrong jetty, and the other because of problems with the
instability of the channel and with boaters using the weir as a
shortcut, creating a safety hazard. According to the Corps, the
problems at these five projects stemmed from inaccurate information on
sand movement when the projects were initially designed. At the sixth
project, more sand has accumulated in the navigation channel than
expected, but this occurred because the Corps did not fully construct
the area designed to collect sand deposits. As a result, according to
the Corps, the navigation channel has been available at its authorized
depth only about 20 percent of the time.
In designing the proposed Oregon Inlet jetty project, the Corps‘
Wilmington District Office applied lessons learned from the
construction of similar jetty projects and from internal Corps
guidance. For example, the Wilmington District staff stated that from
its construction and management of the Masonboro Inlet jetty project in
North Carolina--one of two similar jetty projects that are generally
performing as planned--it learned about the need for dual jetties, the
proper length of a weir, and the effect of erosion on jetties. District
staff stated that from internal Corps guidance they learned about,
among other things, the importance of having accurate information on
sand movement in designing the proposed Oregon Inlet jetty project.
Nonetheless, the Corps stated that because each jetty project is
designed for a unique environment, lessons learned from similar
projects would not predict all aspects of the performance of the Oregon
Inlet project. For example, the Corps incorporated a weir into the
design of Oregon Inlet‘s northern jetty to allow fish larvae that
migrate near the ocean shoreline to travel over the jetty, through the
inlet, and into the sound. None of the eight similar jetty projects
with weirs were designed to provide for fish larvae migration.
Both the Department of Commerce and the Department of the Interior
support the goal of providing a safe navigation channel through Oregon
Inlet for commercial and recreational fishing vessels. However, both
departments support a dredging-only approach to achieve that goal in an
environmentally acceptable manner. Commerce, which manages marine
resources, including fisheries, and Interior, which manages the
federally owned land upon which the jetties would be built, have raised
several environmental concerns about the construction of the Oregon
Inlet jetty project. For example, Commerce believes that constructing
the project will cause unacceptable harm to commercial and recreational
fishery resources by limiting the ability of fish larvae to reach
habitat necessary for their development. Commerce is also concerned
that the jetties will significantly alter sand movement in the vicinity
of Oregon Inlet and damage beaches, dunes, beds of submerged aquatic
vegetation, salt marshes, shallow water habitats, and other aquatic
sites and resources. Interior believes that the jetties will increase
beach erosion, especially on the south side of the inlet, and that the
project‘s sand bypassing system could harm coastline habitat and
wildlife by depositing large quantities of sand onto Interior‘s land
each year without allowing sufficient time for recovery of the
ecosystem. For these and other reasons, Interior has maintained that
constructing the jetties is not consistent with the missions of its
National Park Service (NPS), which manages the Cape Hatteras National
Seashore to the north and south of Oregon Inlet, and Fish and Wildlife
Service (FWS), which manages the Pea Island National Wildlife Refuge to
the south of the inlet, and has denied the Corps the permits needed to
build the jetties on Interior‘s lands. To address the concerns of
Commerce and Interior, the Corps revised its original jetty design to
shorten the length of the jetties and incorporate a weir, which it
believes will mitigate the concerns about fish larvae migration. The
weir is also intended to facilitate the collection of sand, which the
Corps plans to transport to adjacent beaches to address erosion.
However, both Commerce and Interior have stated these actions will not
achieve the desired results. In October 2001, because Commerce,
Interior, and the Corps were unable to reach agreement on these issues,
Commerce referred the matter to the Council on Environmental Quality--
an entity established by the National Environmental Policy Act to
resolve interagency disagreements concerning major federal actions that
might cause negative environmental effects. Interior has also asked the
council to consider its concerns. The Corps does not believe it should
spend additional public resources to develop the project until it has
assurances that the environmental issues will be favorably resolved.
Lacking resolution of environmental concerns from the council and
construction permits from Interior, we agree with the Corps that it
should not pursue further development of the Oregon Inlet jetty
project. If, however, both of these issues are favorably resolved, we
are recommending that in order to have a reliable economic basis for
deciding whether to proceed with the project, the Secretary of the Army
direct the Corps to prepare a new and comprehensive economic analysis
of the project‘s costs and benefits that would provide the more current
and complete information needed to justify construction of the project.
In commenting on a draft of this report, the Departments of the Army,
Commerce, and Interior generally agreed with our findings and
recommendations. The Department of Transportation did not comment on
our overall findings and recommendations, but offered specific
technical comments.
Background:
The Corps‘ mission is both military and civilian and involves providing
quality, responsive engineering services to the nation. The Corps‘
involvement in civil engineering projects, such as the proposed Oregon
Inlet jetty project, comes under the auspices of the Director of Civil
Works and falls into four broad categories: water infrastructure,
environmental management and restoration, response to natural or man-
made disasters, and engineering and technical services. The Corps is
organized geographically into eight divisions and 41 districts that are
responsible for implementing individual projects. The Corps‘
Wilmington, North Carolina, District Office, part of the South Atlantic
Division, is responsible for maintaining a safe and navigable waterway
at Oregon Inlet. Appendix I provides a description of the Corps‘
process for developing a water resource project.
Oregon Inlet provides the only access to the Atlantic Ocean from inland
waters located between Rudee Inlet in Virginia Beach, Virginia, about
85 miles to the north of Oregon Inlet, and Hatteras Inlet in Hatteras,
North Carolina, about 45 miles to the south. Oregon Inlet is located in
the Outer Banks, a string of barrier islands along the coast of North
Carolina. According to a study of Outer Banks sediment and inlet
dynamics, these barrier islands and their migrating inlets consist of
dynamic sedimentary deposits, which, left to nature, constantly move
and change under the influence of waves, currents, and the change in
sea level. Overall, these islands are slowly moving toward the mainland
at an average rate of about 4.5 feet per year. In addition, along the
ocean side of the Outer Banks, the sands flow predominantly toward the
south. For this reason, the islands and Oregon Inlet naturally move in
a southerly direction. At least a dozen separate inlets have naturally
opened and closed along the Outer Banks‘ coastline over the three
centuries that preceded the formation of Oregon Inlet.[Footnote 5]
Currently, there are three inlets along the Outer Banks: Oregon Inlet,
Hatteras Inlet, and Ocracoke Inlet. Figure 1 shows the location of
Oregon Inlet and its surrounding features.
Figure 1: Oregon Inlet‘s Location Along the North Carolina and Virginia
Coastlines:
[See PDF for image]
Source: Corps‘ Wilmington District Office.
[End of Figure]
Oregon Inlet experiences a combination of more high winds, strong
tides, storms, and shifting sand than any other inlet along the
Atlantic coast of the United States. These high-energy conditions often
create hazards for vessels attempting to pass through the inlet to or
from the ocean. Vessels making this passage use the ocean bar
navigation channel, which extends from a point about 1,500 feet inside
the Herbert C. Bonner Bridge (commonly known as the Bonner Bridge) to a
point in the ocean called the ocean bar, about 10,000 feet outside the
bridge.[Footnote 6] At the ocean bar, sand naturally accumulates and
waves break on the surface because of the shallow water. Nonetheless,
hundreds of vessels pass through the inlet each year. In 1999 through
2001, according to North Carolina Division of Marine Fisheries data, on
average, about 311 commercial fishing vessels used Oregon Inlet a total
of about 3,900 times each year to access the ocean. During this period,
commercial fishing vessels using the inlet landed more than 18 million
pounds of fish at seafood dealers that operate inside the inlet.
The North Carolina Department of Transportation is currently evaluating
preliminary plans for constructing a bridge that would replace the
Bonner Bridge. The new bridge would be located farther west than the
current bridge and may make landfall several miles farther south than
the current bridge, possibly bypassing the Pea Island National Wildlife
Refuge. According to a state engineer, the proposed elevated portion of
the new bridge would be 5,000 feet long, which would allow the natural
migration of Oregon Inlet to the south and also permit the navigation
channel to be moved as conditions dictate. The proposed completion date
for the new bridge is 2010. Figure 2 provides an aerial view of Oregon
Inlet.
Figure 2: Aerial View of Oregon Inlet on September 18, 2001:
[See PDF for image]
Source: Adapted from a Corps‘ Wilmington District Office photo mosaic.
[End of Figure]
The safety and navigability of Oregon Inlet has been the subject of a
series of engineering, economic, and environmental studies by the
Corps‘ Wilmington District Office. In the 1960s, local officials and
other interested parties told the Corps that the original 14-foot
navigation channel authorized by the Congress in 1950 was not adequate
because it was not deep enough to accommodate larger vessels and
existing dredging was not sufficient to provide a stable channel at its
authorized dimensions. Subsequently, the House and Senate Public Works
Committees asked the Corps to study whether any modifications of the
Oregon Inlet project were advisable. Based on this work, the Corps made
recommendations that led the Congress to authorize the dual rock
jetties and a 20-foot navigation channel for Oregon Inlet in 1970. The
authorization increased the depth of the ocean bar navigation channel
from 14 feet to 20 feet, in part to accommodate the use of larger,
deep-draft commercial fishing vessels that were expected to use the
inlet in the future.[Footnote 7]
Between the 1970 authorization and September 30, 2001, the Corps‘
Wilmington District Office has spent about $10 million (current
dollars) designing the project and studying whether it was economically
and environmentally sound before construction could begin. These
studies have included at least four updates of the district‘s economic
analyses and four environmental impact statements, as well as various
redesigns of the project. According to the Corps, it has also made a
substantial effort to coordinate its efforts with other interested
agencies. For example, the Corps stated that it has worked with the
Department of Commerce‘s National Marine Fisheries Service and the
North Carolina Division of Marine Fisheries to develop data on fish
catch and associated use of the inlet by commercial fishing vessels.
The Corps also participated in a joint task force with the Department
of the Interior in 1991 to determine the effect of the jetties and the
project‘s proposed sand bypass system on the adjacent shoreline. In
response to concerns raised by the task force, the Corps revised the
proposed project by, among other things, reducing the length of the
jetties and incorporating a weir to facilitate sand bypass and fish
larvae migration. On September 21, 2001, the Corps issued Supplement
No. 2 General Design Memorandum (GDM) and Final Supplement III
Environmental Impact Statement (EIS), which state that the dual jetties
and the 20-foot navigation channel are economically justified and
environmentally acceptable. The Corps document also found that current
dredging efforts at Oregon Inlet have not provided a safe and navigable
ocean bar navigation channel and concluded that hazardous navigation
conditions at the inlet will continue to cause injuries and the loss of
human life as well as vessel damages and losses. However, as of
September 2002, the Congress had not appropriated funds to construct
the jetty project.
Despite the many studies and modifications to the project that the
Corps has made over the last 30 years, the Department of Commerce, the
Department of the Interior, various environmental groups such as the
Biodiversity Legal Foundation, and other interested parties such as the
North Carolina Saltwater Fishing Club, do not believe their concerns
have been adequately addressed by the Corps‘ analysis, and they have
continued to oppose the project. In general, these entities contend
that the Corps‘ economic analysis is unsound and that the jetty project
will cause significant beach erosion and impede migration of fish
larvae to habitat in the sound, potentially leading to a significant
reduction in the overall fish supply. Further, these entities state
that other factors, such as navigational errors, may contribute to the
potential for loss of life at the inlet, a risk that would not be
reduced by construction of the jetties. Commerce and Interior also
anticipate that the project will have adverse impacts to designated
Essential Fish Habitat in the immediate area of Oregon Inlet that is
required by fish for spawning, breeding, feeding, or growing to
maturity.[Footnote 8] However, the jetty project is strongly supported
by the state of North Carolina and the local commercial and
recreational fishing industry, which contend that the project is needed
to ensure safe passage for vessels through the inlet, particularly
larger, deep-draft commercial fishing vessels.
Although the U.S. Coast Guard has not taken an official position on the
project, it is directly involved in issues concerning Oregon Inlet. The
Coast Guard is responsible for maintaining the buoys and markers used
to guide vessels through the ocean bar navigation channel and other
channels in the sounds on the inside of the inlet. Coast Guard units
located in Hatteras, North Carolina, and Portsmouth, Virginia, maintain
the navigation aids at Oregon Inlet. In addition, the Coast Guard
Station Oregon Inlet is responsible for, among other things, search and
rescue and boating safety in coastal waters and sounds from the
Virginia-North Carolina border to approximately Hatteras Island, North
Carolina.
Figure 3 shows the Corps‘ current design for the proposed jetty
project. The project includes construction of dual rock jetties about
3,000 feet apart. The north jetty would be approximately 10,000 feet
long; the south jetty would extend about 3,500 feet beyond the Pea
Island terminal groin, for a total length of about 6,600 feet. The
terminal groin is a rock structure that was completed in 1991 to
protect the southern end of the Bonner Bridge by stabilizing and
restoring the tip of Pea Island. At the time, the erosion of Pea Island
was threatening the southern end of the Bonner Bridge. The project also
incorporates a weir in the north jetty that is designed to serve two
basic purposes: 1) to facilitate sand bypassing from a deposition basin
to adjacent beaches and 2) to aid fish larvae migration from the ocean
past the jetties, through the inlet, and into the sound. A detailed
chronology of significant events related to the development of the
Oregon Inlet jetty project is provided in appendix II.
Figure 3: The Corps‘ Proposed Design for the Oregon Inlet Jetty Project
as of September 2001:
[See PDF for image]
Source: Adapted from Supplement No. 2 General Design Memorandum, Manteo
(Shallowbag) Bay, North Carolina, Corps‘ Wilmington District, September
2001. The map is based on May 26, 1996, aerial photography.
[End of Figure]
Corps Generally Has Not Maintained the Oregon Inlet Ocean Bar
Navigation Channel at Its Authorized Depth:
The Corps has had difficulty maintaining Oregon Inlet‘s ocean bar
navigation channel at its authorized depth of 14 feet. According to
officials in the Corps Wilmington District Office, from August 1983
through March 1994 the 14-foot depth was maintained about 23 percent of
the time.[Footnote 9] During this period, the Corps spent an average of
about $4.1 million annually to dredge the channel. In recent years,
however, expenditures on dredging the channel have declined to an
average of about $2 million annually, and the Corps has been able to
maintain the channel‘s authorized 14-foot depth only about 15 percent
of the time. According to Wilmington District officials, the district
has not been able to maintain the channel‘s authorized depth because
the inlets‘ high-energy environment constantly moves sand back into the
navigation channel and because funding limitations restrict the amount
of dredging that can be performed. Officials said that the district
does not get all of the funds it requests and often has to reallocate
funds that are earmarked for dredging Oregon Inlet to respond to
emergencies elsewhere in the district. The Corps‘ limited dredging and
the high-energy environment of the inlet also affect the Coast Guard‘s
ability to adequately maintain buoys that are supposed to mark the
ocean bar navigation channel for vessels using Oregon Inlet. In fact,
navigation charts for Oregon Inlet do not display the location of
navigation aids, such as buoys, because they are frequently moved by
the Coast Guard due to continuously shifting sand and by severe storms.
These conditions increase the risk of danger to vessels and injuries to
people.
The Inlet‘s Environment and the Corps Limited Resources Have Hindered
Dredging of the Ocean Bar Navigation Channel:
Oregon Inlet experiences more high winds, strong tides, and shifting
sand than any other inlet on the Atlantic coast of the United States.
This high-energy environment is magnified by a high incidence of
storms, particularly those from the northeast (called nor‘easters)
during the fall and winter months. For example, between 1990 and 1998,
the Oregon Inlet area was affected by more than 100 significant storms,
some of them hurricanes. Storms heighten ocean waves and increase sand
movement in the inlet. Based on Corps studies, an average of about 2.1
million cubic yards of sand move in and around Oregon Inlet each
year.[Footnote 10] In comparison, annual sand movement for the two
jettied inlets closest to the Oregon Inlet is about 471,000 cubic yards
for Rudee Inlet in Virginia and about 700,000 cubic yards for Masonboro
Inlet in North Carolina.
In addition to causing massive sand movement each year, district
officials noted that the frequency and severity of storms at Oregon
Inlet significantly affect the district‘s budget and dredging plans.
Specifically, according to district officials, their budget and
dredging plans are prepared 18 to 24 months in advance of the actual
work. However, predicting storms that far into the future is
impossible, and, for this reason, yearly budgets and dredging plans
often differ significantly from actual needs. As a result, the district
has often had to reallocate funds among its projects to meet immediate
needs and is not able to perform all planned activities for Oregon
Inlet, such as dredging. Figure 4 illustrates fluctuations in funding
requested, approved, and expended to dredge the ocean bar navigation
channel.
Figure 4: Funding Requested, Approved, and Expended for Dredging the
Oregon Inlet Ocean Bar Navigation Channel, Fiscal Years 1990 through
2001:
[See PDF for image]
Note: Amounts are expressed in 1997 constant dollars.
Source: GAO analysis of data provided by the Corps of Engineers‘
Wilmington District Office.
[End of Figure]
As shown in figure 4, in some years from 1990 through 2001, the
district did not spend all of the funds that had been approved for
dredging the ocean bar navigation channel; in other years, it spent
more. For example, for 6 of the 12 years, the district received
approval to spend about $22.5 million, but spent about $10.8 million,
or about $11.7 million less than the approved amount. In those years
the district reallocated the $11.7 million budgeted for dredging the
Oregon Inlet ocean bar navigation channel to address other higher-
priority emergency needs in the district. For example, in fiscal year
1999, reallocated funds were used to remove sand bars and debris that
were causing hazardous navigation conditions in the Atlantic
Intracoastal Waterway. These hazards had unexpectedly accumulated after
a severe storm. Conversely, in the other 6 years, the district spent
more funds than were initially approved for dredging the ocean bar
navigation channel. Specifically, the district spent about $25.4
million, or about $6.5 million more than the $18.9 million that had
been initially approved during those years. For example, in fiscal year
1991, the district received approval for about $4.7 million to dredge
the channel, but spent about $7.0 million, which it obtained by
reallocating funds from other projects within the district. District
Office officials explained that in many of these years the district
experienced several hurricanes and other storms that necessitated
redirecting funds from some projects to perform emergency work on other
projects.
Wilmington District Office officials said that another reason they
often need to reallocate funds is because they do not receive all of
the funding that they request. Although district officials noted that
getting requested funding would not ensure that the ocean bar
navigation channel was always maintained at the authorized depth of 14
feet, it would ensure that the authorized depth was maintained more
often and would also reduce the amount of funds that the district has
to reallocate among its projects during emergencies. For example,
between fiscal years 1990 and 2001, the district requested about $55
million for dredging the ocean bar channel and obtained approval to
spend about $41 million, or 75 percent of what it requested.
For the most part, as shown in figure 4, the district has significantly
reduced the amount of funds it has requested and spent on dredging the
ocean bar navigation channel over the last few years. During this
period there has also been a notable decline in the Corps‘ ability to
maintain the channel‘s 14-foot depth. Specifically, between August 1983
and March 1994, when the Corps spent an average of about $4.1 million
per year dredging the channel, it was able to maintain the authorized
14-foot depth about 23 percent of the time. However, between March 1994
and October 2001, the Corps has only maintained the channel at its
authorized depth about 15 percent of the time. District officials
explained that in the late 1980s and early 1990s, the district needed
to dredge a large volume of sand that had accumulated in the navigation
channel around the Bonner Bridge. Due to the location of this sand and
the Corps‘ desire to place it on Pea Island to prevent erosion, the
district used a pipeline dredge to remove the sand. Generally, a
pipeline dredge is significantly more expensive to operate than other
types of dredges because of the cost to set up the pipeline that
transports the removed sand to a new location. By the end of 1995, the
Corps had successfully removed the sand affecting the navigation
channel and deposited it on Pea Island. As a result, according to
district officials, the district reduced its funding requests for 1996
through 2001 because it did not expect to use an expensive pipeline
dredge to remove that much sand again during that period. However,
during that time, there was a reduction in the Corps‘ ability to
maintain the ocean bar navigation channel at its authorized depth.
District officials also said that their budget requests have never
included the total amount of funds needed to maintain the ocean bar
navigation channel at its authorized depth 100 percent of the time.
District officials stated that in the past they could not justify
spending the time and money needed to prepare a request for such an
amount because there was little likelihood that the amount would be
received. However, district officials stated that in their fiscal year
2003 budget request they included a request for $10.9 million, which is
an amount they believe is needed to maintain the channel at 14 feet 100
percent of the time.
Oregon Inlet‘s High-Energy Environment and the Corps‘ Limited Dredging
Have Also Reduced the Coast Guard‘s Ability to Properly Mark the Ocean
Bar Navigation Channel:
The Coast Guard is responsible for maintaining the buoys that mark the
Oregon Inlet channel. Coast Guard officials said that they have
difficulty maintaining the buoys marking the location of deep water in
the ocean bar navigation channel because the high-energy conditions in
the inlet cause large amounts of sand to move in and out of the
channel. This sand movement often changes the location of deep water
and, when combined with the Corps‘ limited dredging, results in sand
accumulation around the buoys. According to the Coast Guard, when sand
accumulates on the channel side of the buoys to a depth that approaches
the draft of a buoy tender, it becomes difficult and sometimes
impossible to relocate the buoys to mark deeper water. For example, on
October 30, 2001, the Coast Guard asked the Corps to provide a vessel
to relocate 6 of the 13 buoys that were located in the inlet at that
time. The Corps vessel could operate in shallower water and had the
lift capability to relocate the buoys.
In addition, as part of an ongoing waterway analysis and management
program, the Fifth Coast Guard District reported on November 14, 2001,
that the buoys in Oregon Inlet are always moving due to storms. The
report states that after every large storm, several buoys at Oregon
Inlet are either damaged, moved, or both, and it is difficult to
maintain and keep these buoys in the proper location because of limited
Coast Guard resources. According to the commanding officer of one of
the Coast Guard vessels that services Oregon Inlet, there is no easy
way to provide a reliable navigational aid system in Oregon Inlet. The
commanding officer said that over the years buoys have been added and
removed in attempts to properly mark the navigation channel, but the
location of deep water changes regularly. The commanding officer also
said that the north side of the channel is almost impossible to mark
reliably because sand regularly shifts into and out of the channel as
Bodie Island moves south, creating a constant navigational hazard.
The buoys that mark the deep water of the ocean bar navigation channel
are frequently moved and are therefore not charted. According to Coast
Guard officials, vessel operators who are not aware of the shifting
sand conditions are susceptible to running their vessels aground. As a
result, the Coast Guard suggests that vessel operators call its Coast
Guard Station Oregon Inlet to obtain the most recent navigation data
before attempting to traverse the ocean bar navigation channel.
Corps‘ Economic Analysis for the Proposed Oregon Inlet Jetty Project
Has Several Limitations That Undermine Its Usefulness:
We identified several limitations in the Corps‘ economic analysis that
undermine its usefulness for assessing whether the Corps‘ preferred
alternative of a dual jetty project with a 20-foot navigation channel
is economically justified. For example, the analysis overstated the
benefits to large commercial fishing vessels (trawlers) based on their
current fishing activities, but did not analyze the potential benefits
the proposed jetty project may provide to smaller commercial fishing
vessels. However, because these smaller vessels have shallower drafts
than trawlers, the extent to which they might benefit from the jetty
project is uncertain. The analysis also did not account for the
economic value of the lives that might be saved by the jetty project,
which could result in understated benefits; it also overstated the cost
of the current dredging program and used an overly optimistic
assumption concerning future dredging needs that would tend to
understate the cost of the jetty project. (See app. IV for more details
on these and other limitations to the economic analysis.) We did not
assess the effects of all these limitations on the net benefits of the
Corps‘ economic analysis because obtaining the necessary data would
require an inordinate amount of time and expense. As a result, we
cannot say what the net effect of addressing all the limitations would
be on the net benefits and the benefit-cost ratio of the Corps‘
preferred jetty project alternative.
Corps Estimate of Benefits to Commercial Fishing Vessels Is Based on
Outdated and Incomplete Data:
The Corps estimated that the recommended jetty project would generate
about $2 million in annualized benefits by reducing the operating costs
of commercial fishing vessels. The Corps anticipates that the
recommended project would reduce these costs by alleviating hazardous
conditions in Oregon Inlet that sometimes force the vessels, especially
trawlers, to detour to more distant inlets or ports. The Corps based
its benefit estimate on the savings that would occur if the number of
detoured trips and their related operating costs were reduced. In
estimating operating cost savings, the Corps included savings in
’fixed“ operating costs, which it defined as including, among other
things, depreciation charges on the vessel, insurance, interest on
loans, and taxes.
In calculating the estimated benefit, the Corps relied on data provided
in a 1987 consultant‘s report that studied the number of trips taken by
trawlers during the mid-1980s.[Footnote 11] However, these data do not
reflect the fewer trips taken by trawlers in recent years. Further, the
Corps overstated the operating costs savings that trawlers would likely
achieve by including all the fixed-costs portions of their hourly
operating costs. The appropriate measure of savings is variable costs
(costs that vary with the length of fishing trips) that would be saved
by reducing the number of detoured trips. This would include the cost
of such items as fuel and oil but not such items as taxes and
insurance, which likely would remain the same whether or not the jetty
project is built.
In addition, by relying on the consultant‘s study, the Corps excluded
from its analysis the trips taken by smaller (shorter than 55 feet)
commercial fishing vessels. These vessels were excluded because the
consultant‘s study did not assess the effect of inlet conditions on the
operating costs of smaller fishing vessels.
As shown in table 1, according to data from the North Carolina Division
of Marine Fisheries, about 97 trawlers averaged 679 trips through
Oregon Inlet from 1999 through 2001.[Footnote 12] By contrast, the
consultant‘s 1987 study found that about 234 trawlers averaged about
4,500 trips through Oregon Inlet from 1984 through 1986. Both the
state‘s data and the 1987 consultant‘s study suggest that the number of
smaller commercial fishing vessels using the inlet has significantly
increased since the mid-1980s. State officials indicated, however, that
because the state and the consultant used different methods to collect
the data--the state‘s data are based on a census of commercial fish
landings and the consultant‘s data were based primarily on interviews
of selected seafood dealers and trawler captains--the state‘s data and
the consultant‘s data may not be fully comparable.[Footnote 13] We
attempted to verify the data used by the consultant, but the Corps no
longer has the supporting documentation for the study. Nonetheless, any
assessment of the effect of the proposed jetty project on commercial
fishing activities should be based on current commercial fishing trip
data, which the state has collected through its trip ticket program. As
a result, the Corps‘ reliance on the consultant‘s 1987 study calls into
question the usefulness of the Corps‘ estimate of the benefits of the
jetty project to commercial fishing vessels.
Table 1: Estimated Average Number of Annual Trips Made by Commercial
Fishing Vessels through Oregon Inlet, for the Periods 1984-1986 and
1999-2001:
Time period: 1994-1986[C]; Trawlers[A]: Number: 234; Trawlers[A]:
Annual trips: 4,498; Trawlers[A]: Number of trips detoured: 1,896;
Trawlers[A]: Landings (million lbs): 15; Smaller vessels[B]: Number: 25
- 30; Smaller vessels[B]: Annual trips: [D]; Smaller vessels[B]: Number
of trips detoured: [D]; Smaller vessels[B]: Landings (million lbs):
2.8.
Time period: 1999-2001[E]; Trawlers[A]: Number: 97; Trawlers[A]: Annual
trips: 679; Trawlers[A]: Number of trips detoured: [D]; Trawlers[A]:
Landings (million lbs): 8.6; Smaller vessels[B]: Number: 214; Smaller
vessels[B]: Annual trips: 3,249; Smaller vessels[B]: Number of trips
detoured: [D]; Smaller vessels[B]: Landings (million lbs): 9.8.
[A] Vessels that are at least 55 feet long :
[B] Vessels that are shorter than 55 feet:
[C] Source: 1987 Kearney/Centaur study:
[D] Not available:
[E] Source: North Carolina Division of Marine Fisheries. :
[End of table]
According to an official with the North Carolina Division of Marine
Fisheries, the change in trawler trips likely reflects changes in
federal and state limits on the fish harvest. For example, in 1992,
several management measures---including a moratorium on the issuance of
new licenses for fishing and a 13-inch limit on the size of fish that
can be harvested---were implemented to reduce over-fishing of flounder,
a fish species traditionally caught by trawlers operating out of Oregon
Inlet. During the mid-1980s, before these resource management measures
were imposed, about 7.7 million pounds of flounder were landed annually
through Oregon Inlet. By contrast, from 1999 through 2001, about 2.2
million pounds were landed annually through Oregon Inlet. According to
Commerce, the size of the commercial fleet has declined due to a vessel
reduction program implemented by the South Atlantic Fishery Management
Council.
Corps officials said that they relied on the methodology of the
consultant‘s 1987 report because they considered it ’independent,“ and
that even though the trips by smaller vessels were not explicitly
included in the analysis, the difficulties experienced by the trawlers
were indicative of all commercial fishing vessels. In addition, the
officials said that the recent trawler trip activity reflects, at least
in part, a decrease in the reliability of the channel due to the lack
of adequate operation and maintenance funds. They also said that the
deeper channel provided by the proposed jetty project might attract
other trawler operators to relocate to the Oregon Inlet area. However,
the Corps‘ assumption about the total hours delayed by inlet conditions
is based on trawler trips, and it is not appropriate to apply the
potential savings to smaller vessels without corroborating evidence
that they, too, are affected in the same way as trawlers. In addition,
while the decrease in trawler traffic may reflect a number of factors,
including fishery management measures and a decrease in the reliability
of the 14-foot channel, the Corps‘ analysis is not useful for assessing
these factors because it relies on data from the mid-1980s that do not
reflect current commercial fishing vessel traffic, the fisheries
management measures that have been put in place since the mid-1980s, or
changes in the reliability of the channel.
To illustrate how using the more recent trawler trip data would affect
the Corps commercial benefits estimate, we adjusted the Corps‘ analysis
to account for the number of fishing trips that trawlers have recently
taken. We also adjusted the Corps analysis to exclude certain fixed
vessel costs. Based on these adjustments, we found that the annualized
commercial fishing benefits would be reduced by about 90 percent, from
about $2 million to $194,000. However, accounting for the effect of the
proposed jetty project on smaller fishing vessels could increase this
adjusted estimate of the benefits to commercial fishing vessels.
Because these smaller vessels have a shallower draft than trawlers,
they may not be as affected by the sand accumulations in the ocean bar
navigation channel that can be hazardous to trawlers. For this reason,
the extent to which smaller vessels might benefit from the jetty
project is uncertain. We could not assess the effect of the proposed
jetty project on the smaller commercial fishing vessels because there
are insufficient data on the extent to which these vessels are delayed
by conditions in the inlet.
Corps‘ Estimate of Benefits Did Not Incorporate the Economic Value of
Accidental Deaths That Might be Prevented by the Proposed Jetty
Project:
The Corps did not incorporate the economic value of the lives that
might be saved by the jetty project into its net benefit estimates.
Consequently, to the extent that the jetty project reduces accidental
deaths, accounting for the economic value of the lives saved could
increase the benefits estimate (all other factors being the same).
Federal guidance on water project analysis does not require that the
economic value of the lives that might be saved by a project be
included in the estimate of net benefits. Nonetheless, it is standard
economic practice to incorporate this economic value into the benefits
estimate so that decision makers can assess the full range of benefits
that might be generated by a federal investment or regulation. For
example, in assessing the benefits of safety improvements that reduce
the risk of premature death, the Department of Transportation uses an
estimate of the ’value of a statistical life,“ which is $3 million per
averted death (2002 dollars).[Footnote 14]
Corps officials said that their policy is to quantify the number of
lives that might be saved by a project but not to estimate their
economic value, because procedures for estimating the economic value of
a life are not included in federal guidelines for analyzing water
projects, and the Corps prefers that the project be assessed without
the influence of the economic benefits attributable to lives saved. The
officials said that they do consider the potential life-saving issues
along with other factors, such as the benefit-cost ratio, in deciding
whether to recommend that a project be implemented. Nonetheless, an
alternative approach that does not require valuation but explicitly
considers lives saved can be useful for assessing whether projects that
have negative net benefits (that is, ’net costs“ when costs exceed
benefits or the benefit-cost ratio is less than 1) may still be worth
implementing. Under this approach, the net costs (exclusive of lives
saved) are divided by the number of lives saved, and the estimate can
be compared with other federal investments to ascertain whether the
proposed project‘s estimate of net cost per life saved is comparable to
that achieved by other federal investments or regulations.
The Corps estimated 14 accidental deaths would be prevented by the
project. However, the Corps‘ analysis assumes that all prior vessel
accidents that included deaths would be prevented by the jetty project
and does not clearly control for factors that would be present with or
without the jetty project. For example, Corps officials told us that
under some weather conditions the inlet would be hazardous even with
the recommended 20-foot channel and dual jetties in place. Further, the
Corps did not control for factors that include changes in type of
vessel traffic, operator experience, and vessel safety technology, all
of which will continue to play a role in the number of accidents and
deaths in the inlet with or without the jetty project. In commenting on
a draft of this report, the Departments of Commerce and Interior noted
that the economic costs of the potential effect of the jetties on
accidental deaths, vessel damage, and personal injuries resulting from
the construction of the jetties are not incorporated in the analysis.
Corps‘ Estimate of Project Cost Does Not Include More Recent Data on
Lower Expenditures and Uses an Overly Optimistic Assumption on Future
Dredging Needs:
Using costs for dredging that the Wilmington District incurred from
fiscal years 1983 through 1996, the Corps‘ economic analysis estimated
that the annualized cost of the current 14-foot dredging program is
about $8.4 million. The $8.4 million includes $6.5 million in average
annual operation and maintenance (O&M) expenditures and about $1.9
million in other costs.[Footnote 15] In contrast, the Corps estimated
that the proposed jetty project would cost $12.9 million ($6.1 million
in O&M costs and $6.8 million in other costs).[Footnote 16] To
determine the incremental or ’net cost“ that would be associated with
implementing the jetty project alternative, the Corps appropriately
subtracted the annualized cost of the current dredging program ($8.4
million) from the annualized cost of the proposed jetty project ($12.9
million). Based on this analysis, the Corps determined that
implementing the jetty project alternative would cost $4.5 million more
annually than the Corps spends on the current dredging program.
The Corps‘ $6.5 million O&M cost estimate for the current dredging
program is based on expenditures from fiscal years 1983 through 1996.
However, for fiscal years 1997 through 2001, the Corps spent only about
$3.9 million per year on dredging. By updating the Corps‘ expenditure
data through fiscal year 2001, we found that the Corps‘ annualized
estimate of the current dredging program would be reduced from $8.4
million to $7.4 million.[Footnote 17] Consequently, the net costs of
the jetty project would increase from $4.5 to about $5.5 million. Corps
officials agreed that dredging expenditures have declined to about $3.9
million annually in recent years for the reasons cited earlier in this
report.
In addition, in estimating the cost of the jetty project, the Corps
excluded $945,000 that it spent from 1983 through 2001 dredging in
Pamlico Sound, which is not part of the ocean bar navigation channel.
The Corps excluded this cost because it assumed that dredging this area
in Pamlico Sound would not be required as part of the recommended jetty
project. Corps officials said that the source of the sand in this area
is the ocean and, based on their best engineering judgment, this area
will naturally flush itself after the jetties are built; therefore,
this dredging cost will no longer be incurred.
However, several coastal engineers and geologists familiar with the
Corps‘ proposed jetty project told us that the jetties would not
eliminate dredging this area of the sound. In general, they believe
that whether the source of the sand is the ocean or rivers that drain
into the sound, the man-made channel will fill back in with the sand
adjacent to it and require dredging. As a result, there is uncertainty
about whether the Corps will continue to dredge this area. Nonetheless,
if the Corps does have to dredge this area, then the cost of the jetty
project would be higher than the Corps estimated in its economic
analysis (all other factors being the same).
Performance of Similar Jetty Projects Has Been Mixed:
Corps district officials identified eight jetty projects located on the
Atlantic Ocean and Gulf of Mexico coastlines that are similar to the
proposed Oregon Inlet project in that they incorporate dual jetties and
a weir. According to data provided by the Corps, two of these jetty
projects, both south of Oregon Inlet on the Atlantic coast, are
generally performing as planned, and six others are not. Two projects
are considered by the Corps to be performing as planned because the
Corps has not had to dredge the project‘s navigation channel more than
originally predicted. For the six jetty projects that are not
performing as planned, one has a navigation channel that is frequently
not at its authorized depth, three have required more dredging and
higher dredging costs than expected,[Footnote 18] and two have had
their weirs closed. According to Corps officials responsible for these
six jetties, a key factor in why these jetties have not performed as
planned was inaccurate information on sand movement when the projects
were initially designed. According to the Corps and other experts, good
estimates of sand movement are essential to successfully designing a
weir jetty project that will facilitate the bypass of sand to adjacent
beaches while ensuring the availability of a navigation channel with
minimum dredging costs. Table 2 summarizes the performance of the eight
dual jetty projects that incorporate weirs.
Table 2: Performance of the Eight Jetty Projects Incorporating Weirs:
Jetty project: Murrells Inlet, SC; Location: Atlantic Ocean Coast; More
dredging than planned: [Empty]; Weir closed: [Empty]; Poor channel
availability: [Empty]; Generally performing as planned: X.
Jetty project: Colorado River, TX; Location: Gulf of Mexico Coast; More
dredging than planned: X; Weir closed: [Empty]; Poor channel
availability: X; Generally performing as planned: [Empty].
Jetty project: Ponce DeLeon, FL; Location: Atlantic Ocean Coast; More
dredging than planned: [Empty]; Weir closed: X; Poor channel
availability: [Empty]; Generally performing as planned: [Empty].
Jetty project: St. Lucie, FL; Location: Atlantic Ocean Coast; More
dredging than planned: [Empty]; Weir closed: [Empty]; Poor channel
availability: X; Generally performing as planned: [Empty].
Jetty project: Perdido Pass, AL; Location: Gulf of Mexico Coast; More
dredging than planned: X; Weir closed: [Empty]; Poor channel
availability: [Empty]; Generally performing as planned: [Empty].
Jetty project: East Pass, FL; Location: Gulf of Mexico Coast; More
dredging than planned: [Empty]; Weir closed: X; Poor channel
availability: [Empty]; Generally performing as planned: [Empty].
Jetty project: Rudee, VA; Location: Atlantic Ocean Coast; More dredging
than planned: X; Weir closed: [Empty]; Poor channel availability:
[Empty]; Generally performing as planned: [Empty].
Jetty project: Masonboro, NC; Location: Atlantic Ocean Coast; More
dredging than planned: [Empty]; Weir closed: [Empty]; Poor channel
availability: [Empty]; Generally performing as planned: X.
Source: GAO analysis of Corps data.
[End of table]
Two Projects Are Currently Performing As Planned:
According to the Corps‘ Charleston District staff, which is responsible
for the Murrells Inlet jetty project, the project has performed as
expected because maintenance dredging of the navigation channel, which
was planned for every 3 years, has only been needed once since the
jetty project was built. That dredging occurred in 1988, and additional
dredging is planned for 2002. District staff said the channel through
the inlet has been kept open primarily by the flushing action of
currents flowing through the jetties and has had lower maintenance
costs than expected.
The Corps‘ Wilmington District staff, which is responsible for the
jetty project at the Masonboro Inlet, said the project is considered to
be performing as planned currently because they have only had to dredge
the project‘s sand deposition basin every 3 or 4 years, which is less
than the planned frequency of once a year. However, the Masonboro Inlet
project was originally constructed in 1966 as a single jetty with a
weir on the north side of the inlet, which did not perform effectively.
The 1,000-foot weir was the first structure of its type to be
constructed in the United States. Tides and current undermined the
jetty because the inlet‘s channel continued to migrate. As a result,
the Corps repaired the first jetty and, in 1980, constructed a second
jetty on the south side of the inlet, which stabilized the locations of
the channel and the sand deposition basin. After the south jetty was
built, however, sand that the Corps predicted would accumulate in the
deposition basin instead began accumulating at the south end of
Wrightsville Beach. This sand eventually formed a spit and required
vessels entering the inlet to make a sharp turn in strong crosscurrents
in order to stay in the navigation channel.[Footnote 19] However, by
using the sand spit as an extended deposition area, the Wilmington
District has only had to dredge the deposition area every 3 or 4 years.
According to district officials, this is also enough dredging to keep
the spit from further encroaching into the navigation channel, which is
otherwise kept open by the currents and tides passing between the
jetties. (See fig. 5 for photographs of the Masonboro Inlet weir.):
Figure 5: The Weir in the North Jetty at Masonboro Inlet, North
Carolina:
[See PDF for image]
The picture on the left shows that high tide covers the weir, while the
picture at the right shows that the weir is exposed at low tide. The
weir‘s elevation is 2.16 feet above mean low water measured at the
inlet.
Source: GAO.
[End of Figure]
Six Projects Are Not Performing As Planned:
Project managers provided the following specific details about four
jetty projects, including the jetty project that has incurred expected
dredging costs, but whose navigation channel is frequently not
maintained at its authorized depth, and the performance of the three
jetty projects that have incurred higher than expected dredging costs.
* At St. Lucie Inlet, Florida, the Jacksonville District was performing
the amount of dredging expected, but more sand accumulated in the
navigation channel than was anticipated because the Corps did not
complete construction of the deposition basin that was to collect the
sand that passes over the weir. As a result, since the jetty project
was constructed, the Corps has been able to maintain the navigation
channel at its authorized depth of 16 feet only about 20 percent of the
time. Plans are under way to complete construction of the deposition
basin. The Jacksonville District believes that construction of the
deposition basin, as well as other modifications to the jetty project,
will help maintain the channel at its authorized depth 100 percent of
the time.
* For the jetty project at Rudee Inlet built by the City of Virginia
Beach, Virginia, officials said they expected to dredge 100,000 cubic
yards of material annually. However, according to the city staff,
actual dredging at the inlet has averaged 300,000 cubic yards annually
because more sand than expected has flowed over the weir. Although the
project has required more dredging than planned, a consultant for the
city of Virginia Beach states that even with higher dredging costs, the
expenditures are justified, because the inlet provides many
recreational and commercial benefits.
* For the jetty project at Perdido Pass (inlet) in Alabama, the Corps‘
Mobile District said that this project was designed for the Corps to
dredge about 100,000 cubic yards of material annually; however, to keep
the navigation channel at its authorized depth, the Corps has actually
had to dredge about 361,000 cubic yards of material every 2 to 3 years.
* For the jetty project at the Colorado River Inlet in Texas, the
Corps‘ Galveston District expected to dredge about 536,000 cubic yards
of sand every 2 years, or an average of 268,000 cubic yards annually.
However, the actual amount of material dredged annually was about
680,000 cubic yards, or about two and a half times what was planned.
The need for this additional dredging occurred because the amount of
sand flowing over the weir has been greater than expected, and the sand
has tended to be deposited in the navigation channel rather than in the
project‘s deposition basin. (See fig. 5 below for a photo of this
project.) Despite the extra dredging, the Corps‘ Galveston District
reported that the channel was available at its authorized depth only
about 30 percent of the time. The need for more dredging than planned
has caused the responsible Corps districts to incur additional
maintenance costs. For example, the Galveston District has spent about
$1.9 million annually for dredging the Colorado Inlet, more than four
times the $425,000 that it planned to spend for annual dredging when
the project was designed.
Figure 6: The Dual Jetty Project at Colorado River Inlet, Texas:
[See PDF for image]
The east jetty is on the right and contains the weir, which is
paralleled by a fishing
walkway. More sand than expected has passed over the weir and been
deposited
in the channel, as indicated by the narrowing of the river in this
view.
Source: The Corps of Engineers‘ Galveston District.
[End of Figure]
The Corps districts had to close the weirs for two of the jetty
projects because they did not work as planned. Specifically, in 1985,
at the East Pass, Florida, jetty project, the Mobile District decided
to fill in the weir that was built in 1969 because the east side of the
weir was eroding, and only a limited amount of sand was accumulating in
the deposition basin. The problem arose because the predominant
direction of the sand flow was opposite to what the Corps expected when
the jetty project was designed. In 1985, after the Corps determined
that the weir was constructed on the wrong jetty, it closed the weir.
In another case, in 1984, the Corps‘ Jacksonville District closed the
weir at Ponce DeLeon Inlet, Florida, because the weir was believed to
be causing erosion problems north of the inlet and instability in the
inlet‘s navigation channel. In addition, the weir caused safety
concerns because boaters were attempting to cross over it to go to and
from the ocean, instead of using the navigation channel. Appendix VI
provides a comparison of the proposed Oregon Inlet jetty project to
similar completed jetty projects.
Corps Applied Lessons Learned from Similar Jetty Projects in Designing
the Oregon Inlet Jetty Project, but Information on Fish Larvae
Migration Is Not Available:
Corps officials at the Wilmington District Office stated that in
designing the Oregon Inlet jetty project, they applied lessons learned
from the construction and management of similar jetty projects and from
internal Corps guidance. Specifically, from experiences gained in
designing, constructing and managing the Masonboro Inlet jetty project
in North Carolina, Wilmington District officials stated that they
learned:
* how to construct dual jetties to avoid problems with channel
migration and to ensure that sand accumulates in the intended area,
* how to determine the proper length of the weir section, and:
* how to design jetties to prevent the structures from being undermined
or weakened by erosion.
In addition to the lessons learned from this actual experience,
Wilmington District officials stated that they used the Corps‘ internal
guidance on the design of jetty projects, which is based on lessons
learned from other Corps projects. Specifically, this guidance
emphasizes the importance of having accurate information on sand
movement in designing a sand bypass system such as the one proposed for
the Oregon Inlet jetty project. Following this guidance, the district
used 20 years of data on sand movement in designing the sand bypass
system for the Oregon Inlet jetty project.
Although the Corps used these lessons in designing the Oregon Inlet
jetty project, there are still some uncertainties about whether the
project will perform as planned. For example, although the Wilmington
District used measurements of sand movement taken over the 20-year
period, these data were obtained from 1956 through 1975 and are now
more than 25 years old. More recent data on sand movement at Oregon
Inlet are available for the period from 1976 through 2001; however, the
Wilmington District has not updated its estimates because it believes
that the new data would not change its existing estimates
significantly. Because this updated data was not included in the
economic analysis, it is uncertain what effect the more recent data
would have on the Corps‘ estimate of sand movement and dredging costs.
Another issue related to sand movement is the accuracy of the models
used to make these estimates. Although the Corps used some of the best
models available to estimate sand movement at Oregon Inlet, Corps
officials acknowledged that these models are imprecise and generate
results that could vary by as much as plus or minus 40 percent. This
variation could affect the actual dredging and sand bypassing costs
that would be incurred if the jetty project were built. To provide for
this uncertainty, the Corps included additional dredging costs of about
$288,000 annually in its economic analysis.
Another uncertainty relates to the impact of the proposed jetty project
on the migration of fish larvae. Although none of the similar jetty
projects with weirs were designed to facilitate fish larvae migration,
the Corps believes that incorporating a weir into the Oregon Inlet
jetty project will minimize the impact of the project on fish larvae.
However, fisheries experts stated that there are no definitive data on
how any jetty projects, with or without weirs, affect fish larvae
migration.
Commerce and Interior Remain Concerned That the Oregon Inlet Jetty
Project Will Harm the Environment:
Both the Department of Commerce and the Department of the Interior
support the goal of providing a safe navigation channel through the
Oregon Inlet for commercial and recreational fishing vessels. However,
both departments support a dredging-only approach to achieve that goal
in an environmentally acceptable manner and have raised several
concerns about the Corps‘ plans for stabilizing the inlet with jetties.
Commerce believes that the Corps‘ environmental impact statement (EIS)
for the project is flawed and that the preferred jetty alternative
would cause unacceptable environmental harm to commercial and
recreational fishery resources. Specifically, Commerce‘s National
Oceanic and Atmospheric Administration (NOAA), which is mandated to
manage the nation‘s living marine resources, believes that the Corps‘
jetty project would eliminate or degrade significant areas of highly
productive fishery habitat, thereby reducing fishery resources.
According to NOAA, such habitat is vital for the development of many
marine species, including shrimp, red drum, summer flounder, and
bluefish, which are found in the Outer Banks. NOAA maintains that the
jetties would alter the near-shore currents and reduce successful
movement of fish larvae, small juvenile fish, and invertebrates, which
are dependent on the currents to carry them into the sheltered
estuaries of the Albemarle and northern Pamlico Sounds. According to
NOAA, this is a particular concern for the economically valuable fish
that spawn offshore in the fall and winter, such as flounder. While
raising these concerns, NOAA recognizes that current data on fish
larvae migration are not sufficient to quantify the impact that the
proposed Oregon Inlet jetties would have on fish larvae migration.
However, NOAA points out that there are no studies or data available on
how weirs or jetties in general affect fish larvae migration, and it
believes that constructing the jetties without this information is an
unacceptable risk. Commerce also noted that without construction of the
jetties, the safety record of vessels using Oregon Inlet has increased
dramatically over the past 20 years.
Interior, which manages the federally owned land on which the proposed
jetties would be constructed, has long opposed the project.[Footnote
20] Interior‘s National Park Service manages the Cape Hatteras National
Seashore, where the proposed northern jetty would be built, and
Interior‘s Fish and Wildlife Service manages the Pea Island National
Wildlife Refuge, where the proposed southern jetty would be
built.[Footnote 21] Since the Corps first prepared an EIS for the
project in 1979, both of these agencies have consistently raised
concerns that the proposed jetties will adversely affect fish and
wildlife habitat. In general, Interior has expressed the following
concerns:
* The jetties will increase beach erosion. Interior stated that if the
jetties are built, erosion and accretion patterns will be modified both
north and south of the inlet, which in turn will increase overwash of
the islands, especially during storms. This overwash will harm valuable
wildlife habitat, as well as plants and vegetation that provide food
for waterfowl and other migratory birds. Interior also stated that this
erosion could exceed the Corps‘ estimates and create a further real
threat of additional construction on Interior land to save the jetties.
Finally, Interior stated that the increased erosion would also threaten
the infrastructure at and adjacent to Oregon Inlet, including state
highway 12. Interior noted that the design of the Bonner Bridge
requires the inlet‘s navigation channel to remain fixed under a single
span of the bridge. However, the proposed replacement bridge currently
being considered by the state has a proposed elevated portion 5,000
feet long that would allow the navigation channel to be moved as
conditions dictate. According to Interior, this would eliminate the
need for the jetties and an existing rock structure (known as the
terminal groin) that was built to protect the southern end of the
Bonner Bridge. Interior stated that under the terms of the permit it
granted to the state to construct the terminal groin, the structure
would probably be removed once the new bridge is constructed.
* The sand bypass system that was designed to mitigate the adverse
effects of beach erosion will permanently alter existing shoreline
habitat and disrupt shorebird nesting, resting, and feeding areas on a
temporary, seasonal, or permanent basis. For example, Interior states
that each sand bypass will harm invertebrate animals (small clams,
worms, and crabs) that inhabit the shoreline and provide a valuable
food source for shorebirds and fish. Interior stated that over the
years frequent sand bypassing of large volumes might permanently
eliminate these food sources and produce severe long-term adverse
impacts on breeding, migrating, and over-wintering shorebirds. Among
these birds are the Great Lakes piping plover population, which is
federally listed as endangered, and the Atlantic/Canada coast piping
plover population, which is federally listed as threatened. There is
also concern that the perpetual placements of incompatible sands will
diminish successful nesting by the threatened loggerhead sea turtle and
green sea turtle. Nesting takes place south of the inlet on the refuge,
which is an area expected to experience the greatest erosion due to the
jetties and therefore would require the most sand placement. In
addition, the trapping and bypassing of the sand will not allow the
sand to naturally migrate into Pamlico Sound, which could have and
adverse effect on intertidal marshes, sandflats, mudflats, and
submerged aquatic vegetation, all of which are important fish and
wildlife habitat.
* The weir will not function as planned. Interior stated that the Corps
has not provided interested agencies with its analysis, studies, or
other data that would support how the weir will perform and notes that
the proposed weir design has not been field-tested. Interior also
expressed concern that the Corps‘ planning has not adequately
considered the impact of the Dare County beach replenishment project on
the weir. Specifically, according to Interior, the project will take,
on average, over one million cubic yards of sand from the ocean and
place it on the beaches north of Oregon Inlet each year. The movement
of this additional sand from the northern beaches southward toward
Oregon Inlet would increase the likelihood of the weir becoming
landlocked, which in turn would allow sand to pass around the north
jetty and into the ocean bar navigation channel. This would increase
the possibility that considerable supplemental dredging would be
required and/or that the Corps may ultimately be required to build
longer jetties, as originally planned. These actions would
significantly increase the cost of the jetty project. Interior also
said that if the weir were to become landlocked, it would nullify the
expected benefit of facilitating the migration of fish larvae.
* Construction of the jetties will diminish much of the public‘s
recreational use of the Bodie Island spit, which, according to
Interior, is contrary to one of the legislative purposes of the Cape
Hatteras National Seashore. Interior stated that the construction of
the north jetty on land of the Cape Hatteras National Seashore would
block access to a large portion of the spit currently used for
recreational activities such as fishing, and a large section of the
spit would be dredged away or used as the site of the proposed sand
deposition basin.
* The jetty project may not significantly reduce the loss of life at
Oregon Inlet. Interior points to data which shows that, in some cases,
the loss of life is not due to conditions at the inlet but rather to
such factors as alcohol consumption, unfamiliarity with the inlet,
navigational errors, and the lack of life vests and survival suits.
According to Interior, these factors would not be corrected by
construction of the jetties. Interior also raised concerns that the
construction of hard structures would introduce a new risk to vessels
traveling through Oregon Inlet, based on accident data from other
jettied inlets.
For these and other reasons, NPS does not support the construction of
the proposed jetty project. NPS stated that the jetty project is not
consistent with its mission of protecting, and it might actually
impair, the resources and values of the Cape Hatteras National
Seashore. Further, in May 1982, the Fish and Wildlife Service issued a
formal determination that the proposed jetty project was not compatible
with the purposes of the Pea Island National Wildlife Refuge, which was
established to manage, protect, and restore migratory birds and other
wildlife.
In addition, in commenting on a draft of the Corps‘ August 2001 final
EIS, the Environmental Protection Agency (EPA) expressed objections to
the EIS that are similar to the concerns of Commerce and Interior.
Specifically, in an October 19, 2001, memorandum to the Corps, EPA
stated that it continues to have objections to the proposed jetty
project. These include concerns about:
* the potential long-term impacts of the project on a regionally
important commercial fishery resource, especially disruptions to larval
fish transport, which EPA believes will be difficult, if not
impossible, to address;
* the adequacy of the Corps‘ proposed mitigation, including whether
there will be sufficient sand available at critical periods to make the
proposed sand management plan function as anticipated in preventing
project-induced erosion of Bodie and Pea Islands;
* the need for the project because of uncertainties associated with
whether the presumed safety benefits will be fully realized; and:
* the assumed economic benefits due to professional disagreements
regarding the assumptions used in the project justification.
EPA believes that the project would result in significant environmental
impacts that should be avoided in order to ensure adequate protection
of the environment and that these significant issues must be addressed
more thoroughly in future deliberations on this project and in the
Corps‘ Record of Decision.
The Corps asserts that in its final EIS it adequately addressed the
concerns raised by Commerce and Interior. Specifically, the Corps said
that it shortened the length of the jetties and incorporated a weir in
the north jetty and a sand bypassing system to address the concerns
raised about fish larvae migration and beach erosion. Furthermore, the
Corps stated that it plans to monitor whether these actions will work
and determine whether additional adverse impacts result from
constructing the jetties. If so, the project will require further
mitigation. However, neither Commerce nor Interior believes that the
Corps‘ proposed actions would satisfy their concerns.
Because of this impasse, in accordance with regulations under the
National Environmental Policy Act, on October 16, 2001, Commerce
formally referred its concerns about the adequacy of the Corps‘ EIS to
the Council on Environmental Quality (CEQ) for its consideration and
action. The referral process permits federal agencies to bring to CEQ
interagency disagreements concerning proposed major federal actions
that might cause unsatisfactory environmental effects. Although
Interior did not formally refer its concerns to CEQ, it sent a letter
to CEQ on November 15, 2001, asking the council to consider whether the
Corps‘ final EIS adequately addressed Interior‘s environmental
concerns.
CEQ may take one or more of several actions, including (1) concluding
that the process of referral and response successfully resolved the
problem; (2) initiating discussions with the agencies with the
objective of mediation; (3) holding public meetings or hearings to
obtain additional views and information; (4) determining that the issue
is not of national importance and requesting the lead and referring
agencies to pursue their own decision processes; (5) determining that
the issue should be further negotiated by the lead and referring
agencies and that the issue is not appropriate for CEQ‘s consideration
until one or more heads of the agencies report to CEQ that the
agencies‘ disagreements are irreconcilable; (6) publishing its findings
and recommendations, including, where appropriate, a finding that the
submitted evidence does not support the position of an agency; and (7)
submitting, where appropriate, the referral and response, together with
CEQ‘s recommendation, to the President for action. CEQ has initiated
discussions with Commerce, Interior, and the Corps, and it held a
public hearing on this issue in December 2001. CEQ is in the process of
completing its assessment and has not established a date for announcing
a final decision.
The Corps does not plan to issue its Record of Decision on the project
until CEQ and GAO issue their final reports. However, the Corps stated
that until these environmental concerns are resolved and Interior
indicates it is willing to grant the Corps the permits needed to build
the project on the federally owned land managed by Interior, the Corps
does not intend to spend additional public resources to further study
the economics of the jetty project for improving the safety and
navigability of Oregon Inlet.
In the meantime, the Corps dredged the Oregon Inlet in 2001 in
accordance with existing NPS and FWS special use permits. In
preparation for the Corps‘ 2002 dredging effort, according to Interior,
NPS and FWS assisted the Corps in the preparation of an environmental
assessment. Based on the cooperatively prepared environmental
assessment, NPS issued a finding of no significant impact and no
impairment to park resources and values. NPS then issued a special use
permit for the 2002 dredging program, which, according to Interior,
includes a 400-foot wide channel that will require dredging away part
of the Bodie Island spit. FWS, likewise, issued the Corps a special use
permit for disposal of dredge material on refuge lands during the
Corps‘ 2002 dredging effort. FWS‘s permit allows the Corps to deposit
about 1 to 2 million cubic yards of dredge spoil on the oceanfront
beaches of the Pea Island National Wildlife Refuge. According to the
NPS special use permit, the dredging operation would also eliminate
approximately 4 acres of wetlands, for which compensatory mitigation
will be provided by the Corps in the form of enhanced wetlands habitat
for migratory shorebirds elsewhere on the Bodie Island spit. The Corps‘
2002 dredging effort is currently underway.
Conclusions:
The Corps states that it has not been able to maintain Oregon Inlet‘s
ocean bar navigation channel at its authorized depth because of the
inlet‘s high-energy conditions, especially during storms, and because
of funding limitations. While it is difficult, if not impossible, to
predict the frequency and magnitude of storms that impact on the
district‘s ability to dredge the channel, the district has not
requested all of the funds it believes are needed to adequately perform
the dredging. Beginning in fiscal year 2003, the district has decided
to request the full amount of funds it believes will allow it to
maintain the channel more reliably.
Although the inlet remains potentially hazardous, we believe that the
Corps‘ economic analysis does not provide a reliable basis for deciding
whether to proceed with the jetty project. We found significant
problems with the analysis, including a reliance on outdated and
incomplete data, the use of unsupported assumptions, and a lack of
accounting for risk and uncertainty in key variables that could
significantly affect the project‘s benefits and costs. In addition to
these economic concerns, the Departments of Commerce and the Interior
do not believe that the Corps has adequately mitigated for
environmental concerns, including the project‘s impact on fish larvae
migration, beach erosion, and wildlife habitat. Commerce has formally
referred its concerns to the Council on Environmental Quality for
resolution. Interior, which also asked the council to consider its
environmental concerns, has been unwilling to grant the Corps the
permits needed to construct the project on Interior‘s lands. For this
reason, the Corps does not believe it should spend additional public
resources reassessing the project‘s economic analysis until it has
assurances that this issue will be favorably resolved. We share the
Corps‘ view that it would not be prudent to spend funds reassessing the
economics of the project until the council resolves the project‘s
environmental concerns and there is some assurance that the Corps will
receive the permits needed to build the project.
Recommendations for Executive Action:
Lacking resolution of environmental concerns from the Council on
Environmental Quality and construction permits from the Department of
the Interior, we agree with the Corps that it should not pursue further
development of the Oregon Inlet jetty project. However, if CEQ
favorably resolves the environmental issues regarding the proposed
jetty project and the Corps receives assurance that it can obtain the
permits from Interior that it needs to build the project, in order to
have a reliable basis for determining whether the project is
economically justified, we recommend that the Secretary of the Army
direct the Corps of Engineers to:
* prepare a new and comprehensive economic analysis of the navigation
project‘s costs and benefits that incorporates updated and complete
data and corrects all errors in calculations and assumptions;
* obtain the information, where possible, that is needed to address the
uncertainties--such as the extent to which the jetty project could
affect the activities of all commercial vessels and the extent to which
areas outside the ocean bar navigation channel could require dredging-
-that could significantly affect project benefits and costs; and:
* submit the revised analysis to the Congress for its use in
considering future appropriations requests for the project.
Agency Comments and Our Evaluation:
We provided a copy of our draft report to the Secretaries of the Army,
Commerce, Transportation, and the Interior, for review and comment.
Overall, the Army, Commerce, and Interior generally agreed with our
findings and the recommendations of the report. The Department of
Transportation did not comment on our overall findings and
recommendations, but offered specific technical comments.
More specifically, the Assistant Secretary of the Army (Civil Works)
stated that the Department concurs with our finding that the Corps has
not been able to maintain a safe navigation channel because of the
inlet‘s high-energy environment and the cost of channel dredging. The
Assistant Secretary also agrees with GAO‘s conclusion and
recommendation that a new economic analysis of the project is needed to
address project uncertainties and provide a reliable basis for deciding
whether to proceed with the project. However, the Assistant Secretary
also agreed that it would not be prudent to expend additional public
funds to conduct an economic reanalysis until CEQ resolves the
environmental concerns about the project and Interior provides
assurances that permits needed to construct the project will be
granted. In addition, the Assistant Secretary concurred with the
information GAO provided on the performance of eight similar jetty
projects, their limitations, and the reasons for those limitations, and
that the information was useful in designing the jetty project.
Finally, the Assistant Secretary stated that the Corps continues to
believe that it has made project design changes and taken adequate
mitigation measures to accommodate Commerce‘s and Interior‘s concerns
and that the jetty project is needed to safely accommodate the large
trawlers that currently operate through the inlet. The Assistant
Secretary stated that GAO‘s discussion of concerns raised by the other
agencies repeats concerns raised in earlier comments and in the CEQ
referral. Accordingly, the Assistant Secretary enclosed a copy of the
Corps‘ response to CEQ. This document is not included with the
Assistant Secretary‘s letter in the report but is available on the Web
at http://www.whitehouse.gov/ceq/referrals.html.
The Department of the Interior generally agreed with our findings,
stating that the report is an objective and thorough analysis of a
complicated project with over three decades of development. It also
agreed with our recommendations, stating that they are consistent with
the departmental position and comments over the past 10 years. The
department also provided clarifications on several technical points,
which have been included in the report as appropriate.
The Department of Commerce noted that the report was thorough, and it
concurred with our findings and recommendations, specifically that
considerable revision of the Corps‘ economic and other analyses are
needed before the feasibility and environmental effects of building
jetties can be determined. The department also offered several specific
comments, which we incorporated, as appropriate, in the report.
The Department of Transportation‘s U.S. Coast Guard provided oral
comments on the draft report. Specifically, the Chief, Waterways
Management Section, District 5, Portsmouth, Virginia, noted that
neither the GAO report nor the Corps‘ economic analysis captured the
Coast Guard‘s costs to maintain the navigation aids at Oregon Inlet
with or without jetties. The official stated that the service the Coast
Guard provides is not free, and that costs should be considered in the
Corps‘ economic analysis of the project. The Chief also noted that
during the past 3 years, the primary buoy-servicing vessel the Coast
Guard uses at Oregon Inlet has increased in length from 157 feet to 175
feet, and its draft has increased from 7 to 9 feet. The Chief stated
that this buoy tender may be the deepest-draft vessel using Oregon
Inlet, and the Corps should consider the Coast Guard‘s operational
needs in its design of a navigation channel. Otherwise, it will become
prudent for the Coast Guard to stop servicing aids to navigation in
Oregon Inlet. We agree that it would be important for the Corps to
assess the Coast Guard‘s costs of maintaining the inlet‘s buoys, with
or without the jetties, when updating its economic analysis. We also
agree that it is important for the Corps to do sufficient dredging to
allow Coast Guard vessels access to the buoys for maintenance.
The full text of the comments provided by the Army, Interior, and
Commerce are included as appendixes VI, VII, and VIII, respectively, in
this report.
Scope and Methodology:
To assess federal efforts to maintain the authorized depth at Oregon
Inlet‘s ocean bar navigation channel, we reviewed documents provided by
the Corps‘ Wilmington District on the frequency and amount of dredging
accomplished since 1960. We discussed this dredging history with
district officials to better understand when and why dredging occurred
and the types of dredges used to maintain the channel. We also reviewed
Corps documents that discuss the dredging history of Oregon Inlet and
show the percentage of time that the district has maintained the
channel‘s authorized depth. We also discussed with district officials
any circumstances that would affect the district‘s ability to dredge
the channel more frequently and thus maintain the authorized depth more
consistently. We also reviewed, analyzed, and discussed the district‘s
budget and planning documents for fiscal years 1990 through 2001 to
ascertain the funding that had been requested, approved, and expended
for dredging the ocean bar channel at Oregon Inlet. We also discussed
and obtained information from the Coast Guard regarding its maintenance
of the navigation buoys at Oregon Inlet to learn of any impediments to
its efforts.
To assess the extent to which the Corps‘ 2001 economic analysis is
useful for decision making, we compared the Corps‘ economic methods and
assumptions with standard principles of economic analysis, including
whether the analysis considered reasonable alternatives, quantified and
monetized all major categories of benefits and costs, measured benefits
and costs relative to a baseline, used data based on current economic
conditions, and accounted for risk and uncertainty associated with key
assumptions and data. In addition, we compared the Corps‘ survey
methods with standard principles for sampling populations and
developing and conducting surveys. We focused our review on the Corps‘
estimates of dredging and jetty costs and on the estimated benefits
that had the greatest impact on the Corps‘ benefit-cost ratio
(commercial fishing, recreational boating, vessel losses and damages,
accidental deaths averted, and land preservation). We discussed the
benefit-cost analysis with Corps officials and, where possible, we
collected supporting documentation from which to verify the Corps‘
analysis. In addition, we reviewed agency and public comments about the
Corps‘ economic analysis. Moreover, we collected updated information
pertaining to the various categories of benefits and costs to ascertain
if conditions had changed that would alter the results of the Corps‘
analysis. For example, to verify Corps and consultant data on lives
lost, vessels lost, and damage at Oregon Inlet and to develop new data,
we obtained information from Coast Guard records to determine which
cases were likely attributable to Oregon Inlet conditions. More details
of our work on the components of the economic analysis are contained in
appendix IV.
To obtain information on the performance of similar jetty projects, we
obtained data from Corps researchers and Corps district offices on
jetty projects at coastal inlets with design features similar to those
planned for Oregon Inlet, mainly dual jetties and incorporated weirs.
We identified eight similar jetty projects--seven built by the Corps
and one built by the City of Virginia Beach, Virginia, for which the
Corps maintains the navigation channel. The eight projects are under
the jurisdiction of six Corps districts: Jacksonville, Florida; Mobile,
Alabama; Wilmington, North Carolina; Galveston, Texas; Charleston,
South Carolina; and Norfolk, Virginia. To collect information on how
these similar jetty projects have performed, we developed a structured
interview document that included a standard list of questions about
each jetty‘s physical features, purpose, and performance
characteristics, such as the operation of the weir and its impacts on
dredging and beach erosion. We then interviewed staff responsible for
the projects to obtain answers to the questions. We did not verify the
answers that district officials provided.
To determine whether the Corps‘ Wilmington District applied lessons
learned from similar jetty projects in its design of the Oregon Inlet
jetty project, we interviewed its engineering staff about the
information they used in developing designs for the proposed Oregon
Inlet jetties. Wilmington staff said they relied in part on lessons
learned from the operations of the jetty project at Masonboro Inlet,
North Carolina, in designing the project for Oregon Inlet. The staff
also identified the Corps‘ internal guidance as helping with the
design. We discussed the lessons learned with the staff and reviewed
Corps planning and engineering documents to verify that the lessons had
been applied. We also discussed with Wilmington District staff, other
federal agency officials, and academic experts (1) the accuracy of
estimates of sand transport used in designing the jetty project and (2)
the potential for applying lessons learned from one jetty project to
another.
To identify concerns raised by the Departments of Commerce and the
Interior about the development of the jetty project, we reviewed
comments on the Corps‘ EIS and design documents and documents developed
by Commerce and Interior that discussed their concerns. We discussed
the concerns with officials in these departments to better understand
the issues. We also met with Wilmington District staff and other
project proponents, such as North Carolina state government officials
and fishing industry representatives, and discussed the departments‘
concerns with them in order to determine the proponents‘ views of these
concerns and to learn of any planned or completed mitigating actions.
We also reviewed the Department of Commerce‘s referral and Department
of the Interior‘s letter and supporting materials sent to the Council
on Environmental Quality citing their objections to the Corps‘ EIS. We
also discussed many of the environmental issues with various opponents
of the project, such as environmental groups and some academic experts,
in order to better understand the issues and their views.
We conducted our work between March 2001 and September 2002 in
accordance with generally accepted government auditing standards.
As arranged with your offices, unless you publicly announce the
contents of this report earlier, we plan no further distribution until
30 days from the report date. At that time, we will send copies of this
report to the Secretaries of Defense, Commerce, and the Interior; the
Director, Office of Management and Budget; and other interested
parties. We also will make copies available to others upon request. In
addition, the report will be available at no charge on the GAO
Web site at http://www.gao.gov. If you or your staffs have any
questions,
please call me at (202) 512-3841. Key contributors to this report are
listed in appendix IX.
(Ms.) Gary L. Jones
Director, Natural Resources and Environment:
Signed By Gary L. Jones:
Appendixes :
Appendix I: The Corps‘ Process for Developing Water Resource Projects:
Generally, the Corps becomes involved in a water resource project when
the local community perceives a need and contacts the Corps for
technical assistance. If the Corps does not have the statutory
authority required to study the project, the Congress must provide
authorization. Generally, this begins with local officials contacting
their congressional delegation. After receiving authorization,
generally through a committee resolution or legislation, and an
appropriation, a Corps district office conducts a preliminary
(reconnaissance) study on how the problem could be addressed and
whether further study is warranted.
If further study is warranted, the Corps typically seeks agreement from
the local sponsor to share costs for a feasibility study. The Congress
may appropriate funds for the feasibility study, including an economic
analysis, which is conducted by the Corps district office. The
feasibility report makes recommendations on whether the project is
worth pursuing and how the water resource problem should be addressed.
In conjunction with the feasibility study, the Corps must also perform
the appropriate environmental study under the requirements of the
National Environmental Policy Act. After public comments on the
environmental study are considered, the Chief of Engineers transmits
the final versions of the environmental and feasibility reports to the
Congress through the Assistant Secretary of the Army for Civil Works
and the Office of Management and Budget. As long as appropriations are
available, the Corps will also prepare a preconstruction engineering
and design report, which is provided to the authorizing committees. The
Congress may authorize the construction of the project in a Water
Resources Development Act or other legislation.
Project construction will occur once the authorized project is included
in the President‘s budget and the Congress appropriates the federal
share of funds to start the project. Upon appropriation of needed
funds, and before construction can begin, the Secretary of the Army and
nonfederal sponsors generally sign a formal project cooperation
agreement. The Corps district office completes the necessary
engineering and design work to develop plans and specifications for
construction. Private contractors managed by the Corps do the
construction work.
[End of section]
Appendix II: Chronology of Significant Events for the Oregon Inlet
Jetty
Project, 1950 through 2002:
Date:
Event:
05/17/50:
P.L. 81-516, The River and Harbor Act of 1950 authorized the Corps to
dredge the ocean bar navigation channel to a depth of 14 feet.
04/17/63:
Committee on Public Works of the U.S. Senate adopts a resolution to
initiate a study of the Oregon Inlet Jetty Project.
09/26/63:
Committee on Public Works of the U.S. House of Representatives adopts a
resolution to initiate a study of the Oregon Inlet Jetty Project.
04/30/69:
Corps submits a favorable report to the Secretary of the Army.
03/18/70:
Secretary of the Army submits the Corps‘ report to the Congress
recommending that the ocean bar navigation channel be deepened from 14
feet to 20 feet, stabilizing Oregon Inlet with jetties, providing a
means for bypassing sand across the inlet, and creating a 15-acre
harbor at Wanchese. The benefit-cost ratio is estimated to be 1.4.
12/31/70:
The River and Harbor Act of 1970, Public Law 91-611, Section 101,
authorizes the Oregon Inlet Jetty Project.
04/15/77:
Corps releases drafts of the Phase I General Design Memorandum (GDM)-
Plan Formulation and Environmental Impact Statement (EIS) for the
project, supporting the basic plan authorized by the Congress.
06/17/77:
Department of the Interior comments on the Phase I GDM and Draft EIS
state that the principal issues involve jetty construction and impacts
on fish larvae migration. The comments state that the proposed project
would result in significant impacts on parklands and that documents do
not adequately address sand bypassing.
07/29/77:
Corps publishes Phase I of the GDM-Plan Formulation.
12/78:
Contract is awarded by North Carolina to enlarge the harbor at
Wanchese.
05/02/79:
Interior meets with the Corps to inform it of the need for special use
permits for construction on Interior lands. The Corps agrees to prepare
a supplement to the Final Environment Impact Statement.
07/12/79:
The Corps sends a letter to the Fish and Wildlife Service (FWS)
Regional Director outlining right-of-way needs for construction,
operation, and maintenance of the jetty project and requesting a
Cooperative Use Agreement for placement of jetties on Pea Island
National Wildlife Refuge.
08/03/79:
The NPS initiates formation of a Coastal Advisory Committee, which
would be known as the Inman Panel.[Footnote 22] Later that month the
panel issues a report outlining the deficiencies in the Corps‘ proposal
and concluding that the project would adversely affect the shoreline
environment.
09/21/79:
The Corps distributes a draft of a Supplement to the Final EIS to
federal agencies, which is later designated as Supplement I. The
purpose of the supplement is to discuss refinement of project features,
correct errors in the earlier EIS, and address environmental concerns.
12/03/79:
Interior provides comments to the Corps on the draft Supplement to the
Final EIS, stating that Interior is not ’in accord with the current
project design.“ The primary concerns of Interior are that (1) the
jetties would accelerate already high rates of erosion near the inlet
and (2) the jetties would alter normal longshore sand transport and
likely cause ’serious erosion problems well beyond the project area.“:
08/07/80:
The Inman Panel releases a second report entitled Potential Effects of
the Proposed Oregon Inlet Jetties on Shore Processes Along the Outer
Banks of North Carolina.
09/80:
The Corps publishes the Phase II GDM-Project Design.
09/09/80:
Interior informs the Corps that neither the National Park Service nor
the FWS finds the jetties consistent with the purpose for which land
under its jurisdiction was established. DOI declines to issue permits
for the jetties and remains opposed to the project.
12/03/80:
The Corps provides Interior with the Phase II GDM. The document
provides revised details on the design and construction of the dual
jetty project and a sand bypassing plan.
12/28/80:
An Interior memo outlines serious environmental concerns regarding the
construction of the jetties, for example, accelerated beach erosion and
blockage of larval fish passage, and expresses doubts about the success
of a Corps sand bypassing program. Interior supports a dredging-only
alternative.
03/81:
North Carolina completes construction of the harbor at Wanchese and a
seafood industrial park.
07/06/81:
Interior Secretary denies permits for the jetty project and states that
this decision is based on the project‘s incompatibility with use of NPS
and FWS lands. The Secretary directs the FWS and NPS to work with the
Corps to develop an alternative to the jetties.
11/24/81:
The Assistant Secretary of the Army (Civil Works) asks Interior for a
decision on the Corps‘ request for permits to use FWS land and the
transfer of jurisdiction of land from the NPS.
12/17/81:
Interior requests that the Corps examine the feasibility of the
dredging-only alternative and that the analysis of a dredging-only
alternative be completed before the Corps pursues the option of jetty
construction.
12/22/81:
The Assistant Secretary of the Army (Civil Works) authorizes the Corps
to undertake a comprehensive evaluation of a dredging-only alternative
recommended by Interior.
05/11/82:
The Corps holds a scoping meeting and announces its intention to
prepare a second supplement to the Final EIS in order to evaluate the
dredging-only alternative recommended by Interior and to design changes
for the jetties.
04/01/83:
The Corps releases its report on the DOI dredging-only plan. The
report, entitled Feasibility Study, Dredging/Near-Shore Disposal Plan,
Oregon Inlet, North Carolina, concludes that Interior‘s dredging-only
alternative is ’functionally infeasible“ because it would produce
’catastrophic and unacceptable“ beach erosion.
04/21/83:
Interior Secretary meets with the Assistant Secretary of the Army
(Civil Works), the North Carolina governor, and the state‘s
congressional delegation. Interior Secretary reiterates that the agency
is unable to issue special use permits for jetty construction on its
land.
06/14/83:
Bills are introduced in the Congress (H.R. 3288 and S. 1471) to
authorize the transfer of land from Interior to the Corps for
construction of the jetty project. Neither bill passes.
09/83:
The Corps publishes Supplement I to the Phase II General Design
Memorandum addressing jetty spacing, structural design, hydraulic
stability, subsurface analysis, sand bypassing, and a reanalysis of
navigation channel dimensions.
02/84:
The Corps publishes an economic analysis of the project as directed by
the Assistant Secretary of the Army (Civil Works) to update an earlier
analysis.
08/13/84:
The Corps issues a draft of Supplement II to the Final EIS. The
document states that the dredging-only alternative with near-shore
disposal has been evaluated and found unacceptable. The preferred
alternative is the dual jetty project with design modifications.
11/14/84:
Interior‘s comments on the draft Supplement II to the Final EIS note
that (1) the dredging-only alternative is not adequately addressed, (2)
the project would accelerate erosion on Pea Island, and (3) the project
may be referred to the Council on Environmental Quality.
12/05/84:
An Office of Management and Budget (OMB) letter to the Corps states
concern that project costs will substantially exceed benefits and that
significant adverse environmental impacts could add to total project
costs. OMB requests an independent analysis.
05/85:
The Corps issues final Supplement II to the Final EIS finding the
dredging-only alternative unacceptable and making the jetties the
preferred alternative of the Corps.
08/14/85:
Interior comments on the Final Supplement II to the Final EIS stating
that, overall, Interior is still opposed to the jetties and supports a
dredging-only alternative.
07/87:
The Kearney/Centaur Company releases A Reassessment of the Economic
Feasibility of the Oregon Inlet Project. This detailed evaluation of
project economics by a consultant hired by the Corps at OMB‘s request
concludes that project costs would exceed benefits.
04/88:
The state of North Carolina submits a report responding to the economic
analysis by Kearney/Centaur.
06/20/89:
FWS issues a right-of-way permit to the North Carolina Department of
Transportation for constructing a terminal groin[Footnote 23] on the
north end of Pea Island National Wildlife Refuge to protect the bridge
over Oregon Inlet. Two days later, the Corps issues permits for
construction.
11/89:
North Carolina awards a contract for construction of the terminal groin
to reduce erosion at north end of Pea Island and protect Bonner Bridge
using the Corps‘ design for a 3,125-foot structure with the same
dimensions and same location as the landward section of the proposed
south jetty.
07/90:
The Corps releases its third economic analysis of project, entitled
1990 Update of 1984 Economic Analysis. This report shows lower initial
construction costs due to the separate construction of the terminal
groin.
12/90:
The Secretary of the Interior sends a letter to the Secretary of the
Army providing criteria the Corps needs to meet to obtain Interior‘s
approval of the project. The criteria include (1) approval of the
project by the Office of Management and Budget; (2) assurance that the
project is legal and compatible with the park and refuge; and (3)
assurance that the project‘s environmental impacts are assessed and
found acceptable.
01/91:
A joint Interior and Corps committee is formed to develop an acceptable
sand management plan.
03/91:
Construction of the terminal groin on Pea Island is completed.
12/31/91:
The joint Interior-Corps committee releases a report evaluating their
differences over the scientific and engineering aspects of the jetty
project. A report by Interior consultants, issued on the same date to
the Secretary of the Interior, concludes that the jetties would have
significant unavoidable large-scale impacts on the inlet and the
adjacent barrier islands and discusses the ecological implications of
project, including the impact on fish larvae migration.
10/28/92:
The Interior Secretary issues two conditional permits to the Corps for
use of Interior lands for jetty construction, contingent on completion
of project plans and environmental studies.
01/28/93:
U.S. Senator Jesse Helms introduces S. 192, a bill that would require
the Corps to carry out the construction and operation of the jetty and
sand transfer system regardless of the final Interior position. The
bill also would exempt the project from any permit requirements,
including those issued by Interior.
06/15/93:
A new Interior Secretary rescinds the conditional permits that would
have allowed the Corps to use Interior lands for the construction of
the Oregon Inlet jetties. The Secretary states that Interior would
revisit this decision when environmental studies on the project have
been completed.
10/94:
The Corps initiates coordination with Interior on the design of a sand
management plan for the Oregon Inlet Project.
01/31/95:
U.S. Representative Walter Jones introduces H.R. 758 entitled the
’Oregon Inlet Protection Act of 1995.“ The bill would require the Corps
to carry out construction and operation of the jetties project. The
bill would allow the Corps to designate the land required for the
project and notify the Interior Secretary of the designation.
07/95:
The Corps releases a Feature Design Memorandum on the sand management
plan that recommends a sand bypassing system that will emulate natural
shoreline processes when the jetties are in place.
07/18/96:
The Senate Subcommittee on Parks, Preservation, and Recreation holds a
hearing on S. 988, a bill directing Interior to transfer administrative
jurisdiction over certain land to the Secretary of the Army to
facilitate construction of the jetties and the sand transfer system.
Interior opposes the bill because of its impact on park and refuge
land. The Assistant Secretary of the Army (Civil Works) testifies that
studies must be completed before construction of the project can begin,
and that it would be premature for the Corps to accept jurisdiction of
the land required for construction. The bill is not passed.
01/04/99:
The Corps releases drafts of Supplement No. 2 to the GDM and Supplement
III to the project EIS. In the EIS, the Corps‘ preferred alternative is
construction of the dual jetty project and implementation of a sand
management plan. In the GDM, the Corps proposes a new jetty design that
shortens each jetty by approximately 1,000 feet, eliminates the sand-
blocking central barrier within each jetty, and adds a 1,000-foot weir
section in the north jetty over which sand is expected to move into a
60-acre deposition basin.
03/04/99:
The National Marine Fisheries Service‘s (NMFS) comments on the January
1999 EIS state that ’the potential for significant and adverse long-
term impacts to nationally important living marine resources is such
that the NMFS has no recourse but to recommend that the jetties not be
built.“:
03/22/99:
Interior‘s comments note deficiencies in Supplement III to the EIS and
reiterate that project goals could and should be met with a dredging-
only program rather than the dual jetty. The comments state that
Interior will consider referring the jetty project to the Council on
Environmental Quality.
05/09/00:
U.S. Senator Jesse Helms attaches a rider (the Oregon Inlet, North
Carolina, Flood Control Improvements) to the fiscal year 2001
Agriculture Appropriations Bill that would have transferred the land to
build the jetties from the jurisdiction of Interior to the Corps.
07/12/01:
FWS provides the Corps with a Final Fish and Wildlife Coordination Act
report for the project. The report recommends that (1) the Corps
abandon plans for a dual jetty project due to the magnitude of
environmental consequences and (2) the Corps develop a dredging-only
program to achieve project goals.
09/01:
The Corps releases final versions of Supplement No. 2 to the GDM and
Supplement III to the project EIS. The Corps‘ preferred alternative
remains construction of the dual jetty project and implementation of a
sand management plan.
10/16/01:
Commerce refers the project to the Council on Environmental Quality
(CEQ), stating that the project‘s construction would cause unacceptable
environmental harm to commercial and recreational fishery resources.
12/12/01:
CEQ holds a public meeting in Manteo, North Carolina, on the dual jetty
and weir system project, receives briefings from involved agencies, and
visits the site of the proposed project.
04/8/02:
The Corps issues an Environmental Assessment for maintenance of the
channel that includes dredging a 600-foot wider channel on the north
side of the inlet, removing 26 acres of Bodie Island, and placing the
dredged material on Pea Island. The assessment and draft Finding of No
Significant Impact are released for a 30-day public comment period.
05/02:
Interior submits comments on the Environmental Assessment for the
channel maintenance, recommending that a 400-foot wider channel be
selected as the preferred alternative in order to minimize ecological
impacts.
07/02:
Interior issues two Special Use Permits--one by NPS and one by FWS--to
the Corps to construct a wider channel on the north side of the inlet,
which would remove over 400 feet of the Bodie Island barrier spit
within the Cape Hatteras National Seashore and deposit the 1 to 2
million cubic yards of dredge spoil on the oceanfront beaches of Pea
Island. The construction would eliminate approximately 4 acres of
wetlands, for which compensatory mitigation will be provided in the
form of enhanced wetland habitat for migratory shorebirds elsewhere on
the Bodie Island spit.
[End of section]
Appendix III: Approved Oregon Inlet Dredging Operations That Were Not
Performed:
As shown in table 3, for some of the fiscal years from 1990 through
2001, the Wilmington District Office did not perform numerous approved
dredging operations in the Oregon Inlet ocean bar navigation channel
and, as a result, did not remove thousands of cubic yards of sand from
the channel. The District Office did not perform these operations
because the funds were used on other, higher priorities within the
district.
Table 3: Approved Oregon Inlet Dredging Operations That Were Not
Performed for Some of the Fiscal Years from 1990 through 2001:
Fiscal year: 1990; Operations not performed: Dredge channel with two
Corps side-cast dredges; Approved funding: $860,000; Cubic yards of
sand planned for removal: Not available.
Operations not performed: Fiscal year : Dredge channel with a hopper
dredge; Approved funding: Fiscal year : $845,000; Cubic yards of sand
planned for removal: Fiscal year : Not available.
Fiscal year: 1994; Operations not performed: Dredge channel with two
Corps side-cast dredges; Approved funding: $1,239,000; Cubic yards of
sand planned for removal: Not available.
Operations not performed: Fiscal year : Dredge channel with a hopper
dredge; Approved funding: Fiscal year : $2,809,000; Cubic yards of sand
planned for removal: Fiscal year : Not available.
Fiscal year: 1996; Operations not performed: Dredge channel with two
hopper dredges; Approved funding: $1,848,000; Cubic yards of sand
planned for removal: 622,216.
Fiscal year: 1998; Operations not performed: Dredge channel with a
Corps side-cast dredge; Approved funding: $664,000; Cubic yards of sand
planned for removal: 601,067.
Operations not performed: Fiscal year : Dredge channel with a hopper
dredge; Approved funding: Fiscal year : $929,000; Cubic yards of sand
planned for removal: Fiscal year : 362,279.
Fiscal year: 1999; Operations not performed: Dredge channel with a
Corps side-cast dredge; Approved funding: $506,000; Cubic yards of sand
planned for removal: 418,958.
Operations not performed: Fiscal year : Dredge channel with a hopper
dredge; Approved funding: Fiscal year : $949,000; Cubic yards of sand
planned for removal: Fiscal year : 164,629.
Fiscal year: 2000; Operations not performed: Dredge channel with three
Corps side-cast dredges; Approved funding: $813,000; Cubic yards of
sand planned for removal: 663,215.
Operations not performed: Fiscal year : Dredge channel with a hopper
dredge; Approved funding: Fiscal year : $201,000; Cubic yards of sand
planned for removal: Fiscal year : 187,984.
Note: Costs are expressed in constant 1997 dollars and reflect unspent
amounts for dredging the ocean bar channel. In addition, there were
some years when the Corps spent more funds than were made available for
dredging but the quantity dredged was 1,889,504 cubic yards less than
was planned. Totals may not add due to rounding.
[A] Actual total exceeds the amount shown because data from some years
were not available.
Source: GAO analysis of data provided by the Corps‘ Wilmington District
Office.
[End of section]
Appendix IV: Review of Corps‘ Economic Analysis of the Proposed Oregon
Inlet Jetty Project:
This appendix reviews the Corps‘ analysis of the benefits and costs of
the recommended jetty project for Oregon Inlet. In general, the Corps‘
analysis has limitations that undermine its usefulness for assessing
the economic tradeoffs between the current 14-foot dredging program and
the Corps‘ preferred alternative of a jetty system with a 20-foot
navigation channel. Specifically, the Corps‘ analysis (1) failed to
consider intermediate channel depths between 14 feet and 20 feet, (2)
used outdated data to estimate the benefits to trawlers and did not
account for the effects of the proposed jetty project on smaller
commercial fishing vessels, (3) used some incorrect and outdated data
to estimate vessel losses and damages, (4) used questionable survey and
sampling techniques to estimate recreational benefits, (5) did not
value land protected from erosion according to federal guidelines, and
(6) did not fully account for risk and uncertainty in key variables
used in the analysis. In addition, we also identified other
limitations, including the fact that the Corps did not account for the
economic value of the lives that might be saved by the jetty project;
in addition, its estimate of project cost does not include more recent
expenditures and is based on an overly optimistic assumption. These
latter limitations are discussed in the report.
The Corps Did Not Consider Alternative Channel Depths between 14 Feet
and 20 Feet:
In conducting its economic analysis, the Corps considered three
alternatives: (1) dredging a 20-foot channel in the spring, (2)
dredging a 20-foot channel in the fall, and (3) constructing dual rock
jetties with a sand bypassing system, along with a 20-foot channel. The
Corps did not analyze intermediate channel depths between the current
14 feet and the authorized 20 feet. As shown in table 4, the Corps
estimated the benefits and costs associated with three 20-foot channel
alternatives--including the proposed jetty project--relative to the
current 14-foot dredging program. Based on this analysis, the Corps
determined that the proposed jetty project would provide greater net
benefits and a higher benefit-cost ratio than either the current
program or the other two 20-foot alternatives. Corps officials said
they considered only alternatives that would achieve the 20-foot
channel depth because analyses the Corps conducted in 1970 and again in
1984 demonstrated that the 20-foot channel was needed to reliably
enable the existing fleet, including 75-foot commercial fishing
vessels, to pass safely through the ocean bar navigation channel. The
Corps‘ 1970 analysis, which served as the basis for the congressional
authorization in 1970, found that that a 20-foot channel would be
economically superior to other channel depths (including 14 feet)
because it would accommodate existing trawlers and attract some
additional trawlers and, therefore, result in the plan that has the
greatest net benefits.
However, federal guidance for evaluating water resource plans such as
the proposed Oregon Inlet jetty project states that alternative plans
should not be limited to those that the Corps could implement under
existing authorities. Alternative plans should be formulated in a
systematic matter to ensure that all reasonable alternatives are
evaluated.[Footnote 24] In addition, according to the state of North
Carolina, trawlers used the inlet far less frequently than smaller,
shallower-draft vessels from 1999 through 2001. For example, of the
approximately 3,900 average annual commercial fishing trips through the
inlet from 1999 through 2001, 83 percent were by smaller commercial
fishing vessels.[Footnote 25] Because these vessels have a shallower
draft, they may not be as dependent as trawlers upon the deeper channel
depths.[Footnote 26] Moreover, although the smaller vessels might
benefit from an increase in the current 14-foot channel depth, the
economically optimal depth, taking into account all vessels (commercial
and recreational) currently using Oregon Inlet, may be less than 20
feet. Consequently, by not including an analysis of the benefits and
costs of intermediate channel depths, the Corps‘ analysis is less
useful for decision making because it does not clearly demonstrate that
the 20-foot channel depth is economically superior to other depths.
Table 4: Comparison of Estimated Annual Benefits and Costs of
Alternatives for Achieving a 20-Foot-Deep Navigation Channel for Oregon
Inlet:
Categories of impacts: Increased benefits; Reduced operating costs of
commercial fishing vessels; Alternatives for achieving 20-foot-deep
channel: Dredging: $2,011,000; Alternatives for achieving 20-foot-deep
channel: Dredging: $2,011,000; Alternatives for achieving 20-foot-deep
channel: Jetty project: $2,011,000.
: Value of increased recreational boating trips; Alternatives for
achieving 20-foot-deep channel: Dredging: : $3,367,000; Alternatives
for achieving 20-foot-deep channel: Dredging: : $3,367,000;
Alternatives for achieving 20-foot-deep channel: Jetty project: :
$3,367,000.
: Reduced costs associated with reduced vessel losses and damages;
Alternatives for achieving 20-foot-deep channel: Dredging: : $552,000;
Alternatives for achieving 20-foot-deep channel: Dredging: : $552,000;
Alternatives for achieving 20-foot-deep channel: Jetty project: :
$552,000.
: Erosion protection; Alternatives for achieving 20-foot-deep channel:
Dredging: : $0; Alternatives for achieving 20-foot-deep channel:
Dredging: : $0; Alternatives for achieving 20-foot-deep channel: Jetty
project: : $1,000,000.
: Value of other categories [A]; Alternatives for achieving 20-foot-
deep channel: Dredging: : $307,000; Alternatives for achieving 20-foot-
deep channel: Dredging: : $307,000; Alternatives for achieving 20-foot-
deep channel: Jetty project: : $307,000.
: Accidental deaths prevented (over 50 years); Alternatives for
achieving 20-foot-deep channel: Dredging: : 14; Alternatives for
achieving 20-foot-deep channel: Dredging: : 14; Alternatives for
achieving 20-foot-deep channel: Jetty project: : 14.
: Total increased benefits; Alternatives for achieving 20-foot-deep
channel: Dredging: : $6,237,000; Alternatives for achieving 20-foot-
deep channel: Dredging: : $6,237,000; Alternatives for achieving 20-
foot-deep channel: Jetty project: : $7,237,000.
Categories of impacts: Increased costs; Construction and maintenance;
Alternatives for achieving 20-foot-deep channel: Dredging:
$10,601,400; Alternatives for achieving 20-foot-deep channel:
Dredging: $8,148,400; Alternatives for achieving 20-foot-deep channel:
Jetty project: $4,520,000.
Categories of impacts: Net benefits (increased benefits minus increased
costs); [Empty]; Alternatives for achieving 20-foot-deep channel:
Dredging: -$4,364,400; Alternatives for achieving 20-foot-deep
channel: Dredging: -$1,911,400; Alternatives for achieving 20-foot-
deep channel: Jetty project: $2,717,000.
Categories of impacts: Benefit-cost ratio (increased benefits divided
by increased costs); [Empty]; Alternatives for achieving 20-foot-deep
channel: Dredging: 0.59; Alternatives for achieving 20-foot-deep
channel: Dredging: 0.77; Alternatives for achieving 20-foot-deep
channel: Jetty project: 1.6.
[A] Includes categories such as charter boat income and reduced
maintenance of navigation aids.
Source: U.S. Army Corps of Engineers 2001 General Design Memorandum.
[End of table]
Corps‘ Analysis of Benefits to Commercial Fishing Vessels Relied on
Outdated Trip Data and Excluded Certain Vessels:
In its 2001 General Design Memorandum, the Corps determined that the
proposed jetty project would generate about $2 million in annualized
commercial fishing benefits. To derive this estimate, the Corps relied
primarily on a 1987 consultant‘s study of trawler trips taken in the
mid-1980s. That study determined that 234 trawlers were forced to
detour to alternative inlets or ports on average about 42 percent of
the time, adding about 14 hours to the length of their fishing trips.
Thus, the study estimated that trawlers lost about 27,163 hours
detouring to alternative inlets. Assuming that the proposed jetty
project would save commercial fishing vessels these hours, the Corps
multiplied the hours by an estimate of the hourly cost to operate a
commercial fishing vessel ($80.21, including fixed and variable
operating costs) to estimate the value of the time savings as
$2,179,000. The Corps divided $2,179,000 by the 17.9 million pounds of
fish estimated to have been landed through Oregon Inlet by all
commercial vessels in the mid-1980s to obtain the per-pound savings of
12.2 cents. The Corps then applied the per-pound savings to two
different estimates of long-term fish harvests: one based on
projections developed by the National Marine Fisheries Service and one
based on projections developed by the state of North Carolina. In
addition, the Corps conducted an uncertainty analysis on each
projection to incorporate variability in natural fish populations and
the effectiveness of management plans. Based on the two projections and
the uncertainty analysis, the Corps estimated that from 16,758,000 to
23,313,000 pounds of fish could be available for harvest annually over
the 50-year life of the jetty project. Multiplying these projections by
the per-pound savings of about 12.2 cents, the Corps estimated that
annualized benefits of the proposed jetty project would range from
$2,011,000 to $2,798,000.
However, recent data from the state of North Carolina Division of
Marine Fisheries commercial fishing trip ticket program suggest that
trawlers are taking fewer trips than they did in the mid-1980s.
Moreover, trawlers would not likely save the fixed-costs portion of
their hourly operating costs even if the proposed jetty project were
built.[Footnote 27] To illustrate how the Corps‘ benefit estimate would
change using the more recent trawler trip data, we adjusted the Corps‘
commercial fishing vessel benefits analysis to account for trawler
trips taken from 1999 through 2001. In addition, we adjusted the Corps‘
analysis to exclude the fixed costs that would not likely be affected
by the proposed jetty project. After making these adjustments, we found
that the Corps estimate of commercial benefits would be reduced by
about 90 percent. Nonetheless, the Corps‘ analysis excludes smaller
commercial fishing vessels; including these vessels could increase this
adjusted estimate of benefits.
For example, according to data obtained from the state of North
Carolina, vessels 55 feet or longer (defined by the Corps as trawlers)
averaged 679 trips through the inlet from 1999 through 2001.[Footnote
28] Based on these trips and the 1987 consultant‘s estimate of the
fraction (0.42) of trips delayed and the average length of the delay
(14 hours), trawlers might have been delayed by about 4,000 hours
annually over this period. Multiplying the hours delayed (4,000) by the
Corps‘ hourly operating cost for a trawler (about $68.00 per hour,
exclusive of fixed costs) gives an estimated potential annual savings
of about $272,000. Dividing the annual savings ($272,000) by the
average number of pounds landed by trawlers through Oregon Inlet from
1999 through 2001 (8.6 million pounds or 39 percent of the total
commercial landings) provides potential savings of about 3 cents per
pound. We applied the fraction (0.39) of trawler catch to the Corps‘
two projections of future fish harvests to obtain an estimate of the
pounds of fish that trawlers would be expected to harvest based on
current data. For example, based on the current harvest data and the
long-term projections developed by the Corps, trawlers might harvest
from about 6,500,000 pounds to 9,100,000 pounds of fish annually. We
multiplied the two estimates of the trawler harvest by 3 cents to
obtain the estimate of annual operating cost savings. We then estimated
the present value and annualized over the 50-year period using the
Corps‘ discount rate of 7.125 percent. Thus, adjusting the Corps‘
analysis in this way generates annualized benefits ranging from about
$194,000 to $270,000, or about 90 percent less than the Corps
estimated.[Footnote 29]
The Corps used two other methods to verify the analysis conducted using
the consultant‘s 1987 study. First, the 2001 GDM refers to a 1990 Corps
economic analysis that found commercial fishing vessels were delayed by
17,666 hours because of Oregon Inlet conditions, incurring additional
costs of 11.4 cents per pound to land fish. However, the Corps estimate
is not based on the number of trips or landings made by trawlers in
recent years. Second, based on a 1995 study by a consultant, the Corps
assumed that 56 full-time vessels were forced to detour eight trips per
year. In addition, the Corps assumed that other vessels would use
Oregon Inlet if the jetty project were built. For example, the Corps
assumed that 100 additional part-time and/or transient vessels would
use Oregon Inlet to land fish and another 100 vessels would use Oregon
Inlet seeking a harbor of refuge during storms. However, the Corps
could not provide us with the documentation to verify the number of
full-time vessels, total trips taken, trips detoured, number of
transient vessels using the inlet, or the number of vessels that might
seek refuge during storms.
Accounting for the effect of the proposed jetty project on smaller
fishing vessels could increase this adjusted estimate of the benefits
to commercial fishing vessels. Nonetheless, because these smaller
vessels have a shallower draft than trawlers, they may not be as
affected by the sand accumulations in the ocean bar navigation channel
that can be hazardous to trawlers. For this reason, the extent to which
smaller vessels might benefit from the jetty project is uncertain. In
addition, to the extent that trawlers relocate from other fishing ports
(for example, Norfolk) to Wanchese, North Carolina, as a result of the
jetty project, estimated benefits to trawlers could be higher (after
netting out transfers between the two regions). Moreover, to the extent
that trawler captains are detoured or delayed more or less often than
we assumed, the estimated benefits could be higher or lower. Several
trawler captains told us that there are fewer detours available to them
than in the past. According to these captains, the Ocracoke Inlet and
the Atlantic Intracoastal Waterway from Norfolk, Virginia, to Wanchese,
North Carolina, are too shallow for trawlers to use as a way to avoid
passing through Oregon Inlet. These captains said that instead of
traveling to alternative inlets or ports, they often wait for high tide
at Oregon Inlet in order to increase the distance between the keel of
their vessel and the channel bottom. By waiting for high tide, vessels
might be delayed less time per trip than is assumed in either the
Corps‘ analysis or this adjusted analysis. However, no comprehensive
data are available with which to verify the average length of time
vessels are currently delayed or to evaluate the effects of conditions
in Oregon Inlet on the operating efficiency of the current trawler
fleet or smaller commercial fishing vessels.
Corps‘ Estimate of Vessel Losses and Damages Is Based on Unsupported
Assumptions and Outdated Data:
The Corps estimated that the recommended jetty project would generate
annualized benefits of $552,000--$160,000 in reduced vessel losses and
$392,000 in reduced damages to commercial fishing vessels. The Corps
anticipates that the jetty project would generate these benefits by
reducing the high waves and sand accumulations in the inlet that
contribute to vessel losses and accidents. However, the Corps‘ estimate
has limitations that raise questions about its reliability.
The first limitation is that the Corps‘ analysis assumes that all prior
accidents would be prevented by the jetty project and does not clearly
control for factors that would be present with or without the jetty
project. For example, Corps officials told us that under some weather
conditions the inlet would be hazardous even with the recommended 20-
foot channel and dual jetties in place. Further, factors the Corps did
not control for include changes in type of vessel traffic, operator
experience, and vessel safety technology, all of which will continue to
play a role in the number of accidents in the inlet, with or without
the jetty project. For example, as mentioned earlier, the number of
trips by trawlers between 1999 and 2001 is 85 percent less than the
number of trips taken in the mid-1980s, and the Corps‘ analysis does
not reflect this change.
Second, the Corps estimate of $160,000 in annualized benefits from
reduced vessel losses is based on outdated data, some of which are
incorrect and some of which we could not verify. The GDM states that
the Corps‘ estimates of vessel losses and damages evolved from prior
studies and the analyses of two consultants‘ reports. With regard to
vessel losses, a consultant‘s report completed in 1987attributed the
loss of 21 vessels between 1961 and 1986 to conditions in Oregon
Inlet.[Footnote 30] The Corps used this information to estimate vessel
losses in its 1990 economic analysis.[Footnote 31] Subsequently, a 1995
consultant‘s report estimated that the jetty project would prevent the
loss of 14 vessels during the 50-year life of the project.[Footnote 32]
This report updated data in prior studies, including the 1990 economic
update by the Corps, and made adjustments because of reductions in the
number of large fishing vessels using the inlet. However, unlike the
1987 consultant‘s report, the 1995 consultant‘s report did not identify
specific vessels lost or explain its basis for arriving at its estimate
of 14 vessels. For its 2001 economic analysis, the Corps relied on the
1995 consultant‘s report that assumed the 20-foot channel and dual
jetties would prevent the estimated loss of 14 vessels.
We asked the Corps to provide us with the supporting documentation
behind two previous economic analyses completed in 1987 and 1990. Corps
officials could not provide this information, stating that the data may
have been lost or discarded when the office relocated. The 1987
consultant report did, however, list the names of the vessels lost
between 1961 and 1986 that it attributed to conditions in Oregon Inlet.
Accordingly, we asked the Coast Guard for any available accident
investigation reports regarding these vessels. The Coast Guard had no
records for 12 of the 21 vessels that the consultant report listed as
lost. As shown in table 5, of the nine accident investigation reports
we reviewed, six of the losses were probably attributable to inlet
conditions. Of the three losses that we found not attributable to the
inlet, two occurred at locations other than Oregon Inlet and one was
caused by mechanical failure. Because we found that three of nine
vessel losses--33 percent--were not attributable to the inlet, we have
concerns about the overall accuracy of the data in the report. Since it
is unclear how information from the Kearney/Centaur report was used in
updating the estimates of vessel losses for the Horizon Group report
and the estimates of vessel losses in Corps‘ latest economic analysis,
we cannot determine the exact impact of the errors from the 1987 report
on the Corps‘ estimate.
Table 5: Summary of Information in U.S. Coast Guard Investigation Files
on Vessel Losses at Oregon Inlet, 1961 through 1986:
Date of the accident: 10/13/77; Vessel name and identification number:
M/V Tosco,; 505450; Location of the accident: The 7[TH] span south of
the center of Bonner Bridge at Oregon Inlet.; Estimated value of lost
vessel and contents: $100,000 for the vessel; $9,000 for the fish
catch; Was the accident caused by Oregon Inlet conditions?: Yes; Value
of the loss in constant 1997 dollars: $246,830.
Date of the accident: 11/01/77; Vessel name and identification number:
F/V Miss Chievious Too, 582529; Location of the accident: Not specific,
assumed to occur in Oregon Inlet or Pamlico Sound as the vessel was
entering to find safe moorage.; Estimated value of lost vessel and
contents: $40,000 for the vessel; Was the accident caused by Oregon
Inlet conditions?: Yes; Value of the loss in constant 1997 dollars:
$90,580.
Date of the accident: 02/09/79; Vessel name and identification number:
F/V Dolphin, 258728; Location of the accident: The vessel sank in the
Atlantic Ocean 9 miles southeast of Hatteras Inlet.; Estimated value of
lost vessel and contents: $40,000 for the vessel; $2,000 for the fish
catch; Was the accident caused by Oregon Inlet conditions?: No. The
accident did not occur in Oregon Inlet.; Value of the loss in constant
1997 dollars: [A].
Date of the accident: 08/25/79; Vessel name and identification number:
F/V Ole Ugly, 265219; Location of the accident: After departing through
Ocracoke Inlet, the vessel sank in the Atlantic Ocean.; Estimated value
of lost vessel and contents: $250,000 for the vessel; Was the accident
caused by Oregon Inlet conditions?: No. The accident did not occur in
Oregon Inlet.; Value of the loss in constant 1997 dollars: [A].
Date of the accident: 12/31/81; Vessel name and identification number:
F/V Coral Breeze, 543963; Location of the accident: At Oregon Inlet‘s
ocean bar.; Estimated value of lost vessel and contents: $170,000 for
the vessel; $6,500 for the fish catch; Was the accident caused by
Oregon Inlet conditions?: Yes; Value of the loss in constant 1997
dollars: $288,493.
Date of the accident: 12/07/81; Vessel name and identification number:
F/V Lady Phyllis, 618355; Location of the accident: The vessel hit the
Bonner Bridge.; Estimated value of lost vessel and contents: $4,000 for
the vessel; Was the accident caused by Oregon Inlet conditions?: No.
Inlet conditions were calm. Incident was caused by mechanical failure.;
Value of the loss in constant 1997 dollars: [A].
Date of the accident: 12/12/82; Vessel name and identification number:
F/V Lois Joyce, 605933; Location of the accident: In the Oregon Inlet
channel 150 feet outside buoy number 4.; Estimated value of lost vessel
and contents: $850,000 for the vessel; Was the accident caused by
Oregon Inlet conditions?: Yes; Value of the loss in constant 1997
dollars: $1,307,894.
Date of the accident: 12/04/85; Vessel name and identification number:
F/V Elizabeth Christine, 277218; Location of the accident: Within
Oregon Inlet longitude and latitude coordinates.; Estimated value of
lost vessel and contents: $150,000 for the vessel; Was the accident
caused by Oregon Inlet conditions?: Yes; Value of the loss in constant
1997 dollars: $207,526.
Date of the accident: 06/22/86; Vessel name and identification number:
F/V Marlina, 249132; Location of the accident: Within Oregon Inlet
longitude and latitude coordinates.; Estimated value of lost vessel and
contents: $35,000 for the vessel; Was the accident caused by Oregon
Inlet conditions?: Yes; Value of the loss in constant 1997 dollars:
$47,374.
Date of the accident: Total; Value of the loss in constant 1997
dollars: $2,188,697.
[A] Not calculated because the accident was not caused by Oregon Inlet
conditions.
Source: Case files retrieved by Marine Casualty Investigation Division
and printouts of electronic marine casualty reports from the Data
Administration Division, U.S. Coast Guard.
[End of table]
Moreover, based on our review of more current Coast Guard records, from
1986 through 2001, we identified the loss of four vessels that were
likely attributable to inlet conditions. These are listed in table 6.
Therefore, based on our review of the Coast Guard reports that were
located on past cases and by updating this data using more current
records, we identified 10 vessel losses that occurred because of inlet
conditions between 1977 and 2001. The total value of these 10 vessels
is about $2.4 million, or roughly $96,000 per year over that 24-year
period, which is 40 percent less than the Corps‘ estimate of $160,000
per year in annualized benefits.[Footnote 33]
Table 6: Listing of Vessel Losses and Deaths Attributed to Conditions
at Oregon Inlet, June 28, 1986, through November 27, 2001:
Date of the incident: 01/13/89; Vessel name and/or identification
number: NC8559AS; Type of vessel: Fishing; Vessel length: 30; Number of
deaths: 0; Value of the loss reported: $30,500; Value of the loss in
constant 1997 dollars: $37,341.
Date of the incident: 12/30/92; Vessel name and/or identification
number: High Liner, D620483; Type of vessel: Fishing; Vessel length:
28; Number of deaths: 0; Value of the loss reported: $50,320; Value of
the loss in constant 1997 dollars: $55,855.
Date of the incident: 11/20/96; Vessel name and/or identification
number: NC9186BK; Type of vessel: Recreational; Vessel length: 17;
Number of deaths: 1; Value of the loss reported: 0; Value of the loss
in constant 1997 dollars: 0.
Date of the incident: 05/06/00; Vessel name and/or identification
number: Little Fly Fisherman, D287083; Type of vessel: Recreational;
Vessel length: 40; Number of deaths: 0; Value of the loss reported:
$130,000; Value of the loss in constant 1997 dollars: $123,821.
Date of the incident: 11/27/01[A]; Vessel name and/or identification
number: NC9367DA; Type of vessel: Recreational; Vessel length: 16;
Number of deaths: 1; Value of the loss reported: $8,500; Value of the
loss in constant 1997 dollars: $7,934.
Date of the incident: Total; Vessel name and/or identification number:
[Empty]; Type of vessel: [Empty]; Vessel length: [Empty]; Number of
deaths: 2; Value of the loss reported: $219,320; Value of the loss in
constant 1997 dollars: $224,951.
[A] While we reviewed U.S. Coast Guard records from June 28, 1986,
through September 30, 2001, we included a fatal accident that occurred
in November 2001.
Source: U.S. Coast Guard and North Carolina Wildlife Resources
Commission.
[End of table]
The third limitation we identified to the Corps‘ analysis involves the
estimated annualized benefits of $392,000 in reduced vessel damages if
the jetty project is built. Again, the Corps relied partly on data
developed in the 1987 consultant‘s study.[Footnote 34] To estimate the
value of damages to vessels, the consultant interviewed vessel captains
and marine repair yards and determined that the average annual damage
per vessel due to inlet conditions was about $7,000. The Corps then
multiplied this figure by the number of full-time commercial fishing
vessels that it estimated were using the inlet, which it determined to
be 56 full-time vessels, to arrive at $392,000 in reduced vessel
damages. In its estimate, the Corps assumed that all trawlers using the
inlet would sustain damages each year. The Corps could not provide
documentation for this assumption. In contrast, as shown in table 7,
our analysis of Coast Guard data over this period showed that only 10
commercial fishing vessels 55 feet and longer reported damages, which
totaled on average about $1,700 per year.
Table 7: Listing of Vessel Damages Attributed to Conditions at Oregon
Inlet between June 28, 1986, and September 30, 2001:
Date of the incident: 07/04/86; Vessel name and/or identification
number: Northerly Island, D664129; Type of vessel: Dredge; Vessel
length: 194; Number of injuries: 0; Value of the damage reported:
$75,000; Value of the damage in constant 1997 dollars: $101,516.
Date of the incident: 10/14/86; Vessel name and/or identification
number: Capt. Weddell, D654888; Type of vessel: Fishing; Vessel length:
74; Number of injuries: 0; Value of the damage reported: 0; Value of
the damage in constant 1997 dollars: 0.
Date of the incident: 06/12/87; Vessel name and/or identification
number: God‘s Mercy, D561112; Type of vessel: Fishing; Vessel length:
77; Number of injuries: 0; Value of the damage reported: 0; Value of
the damage in constant 1997 dollars: 0.
Date of the incident: 04/04/88; Vessel name and/or identification
number: Schweizer, CG010063; Type of vessel: Dredge; Vessel length:
133; Number of injuries: 0; Value of the damage reported: $40,000;
Value of the damage in constant 1997 dollars: $50,832.
Date of the incident: 05/05/88; Vessel name and/or identification
number: Kokina, D585863; Type of vessel: Fishing; Vessel length: 72;
Number of injuries: 0; Value of the damage reported: 0; Value of the
damage in constant 1997 dollars: 0.
Date of the incident: 05/26/88; Vessel name and/or identification
number: Boss Lady, D505741; Type of vessel: Fishing; Vessel length: 82;
Number of injuries: 0; Value of the damage reported: $15,000; Value of
the damage in constant 1997 dollars: $19,062.
Date of the incident: 04/15/89; Vessel name and/or identification
number: Mermentau, D643740; Type of vessel: Dredge; Vessel length: 197;
Number of injuries: 0; Value of the damage reported: 0; Value of the
damage in constant 1997 dollars: 0.
Date of the incident: 10/26/90; Vessel name and/or identification
number: Northerly Island, D664129; Type of vessel: Dredge; Vessel
length: 194; Number of injuries: 0; Value of the damage reported:
$6,500,000; Value of the damage in constant 1997 dollars: $7,658,772.
Date of the incident: 09/07/92; Vessel name and/or identification
number: Uncloudy Day, D950979; Type of vessel: Fishing; Vessel length:
55; Number of injuries: 0; Value of the damage reported: $3,000; Value
of the damage in constant 1997 dollars: $3,330.
Date of the incident: 01/13/94; Vessel name and/or identification
number: Louise, MS4131AP; Type of vessel: Fishing; Vessel length: NA;
Number of injuries: 0; Value of the damage reported: 0; Value of the
damage in constant 1997 dollars: 0.
Date of the incident: 04/27/94; Vessel name and/or identification
number: Lucky Thirteen, D606275; Type of vessel: Fishing; Vessel
length: 65; Number of injuries: 0; Value of the damage reported: 0;
Value of the damage in constant 1997 dollars: 0.
Date of the incident: 07/22/94; Vessel name and/or identification
number: Gallant Fox, D567254; Type of vessel: Fishing; Vessel length:
72; Number of injuries: 0; Value of the damage reported: $1,000; Value
of the damage in constant 1997 dollars: $1,062.
Date of the incident: 04/07/95; Vessel name and/or identification
number: Portugal, D608405; Type of vessel: Fishing; Vessel length: 74;
Number of injuries: 0; Value of the damage reported: 0; Value of the
damage in constant 1997 dollars: 0.
Date of the incident: 10/08/95; Vessel name and/or identification
number: Hoosier State, D581970; Type of vessel: Tug; Vessel length: 43;
Number of injuries: 0; Value of the damage reported: 0; Value of the
damage in constant 1997 dollars: 0.
Date of the incident: 12/07/95; Vessel name and/or identification
number: Clayton Reed, D683286; Type of vessel: Fishing; Vessel length:
45; Number of injuries: 0; Value of the damage reported: $6,000; Value
of the damage in constant 1997 dollars: $6,236.
Date of the incident: 12/11/95; Vessel name and/or identification
number: Atchafalaya, D630005; Type of vessel: Dredge; Vessel length:
197; Number of injuries: 0; Value of the damage reported: 0; Value of
the damage in constant 1997 dollars: 0.
Date of the incident: 06/03/97; Vessel name and/or identification
number: Hooker, D592896; Type of vessel: Passenger; Vessel length: 46;
Number of injuries: 1; Value of the damage reported: 0; Value of the
damage in constant 1997 dollars: 0.
Date of the incident: 11/02/99; Vessel name and/or identification
number: War Cry, D614462; Type of vessel: Recreational; Vessel length:
76; Number of injuries: 0; Value of the damage reported: 0; Value of
the damage in constant 1997 dollars: 0.
Date of the incident: 12/31/99; Vessel name and/or identification
number: Capt. Malc, D607993; Type of vessel: Fishing; Vessel length:
81; Number of injuries: 0; Value of the damage reported: $300; Value of
the damage in constant 1997 dollars: $292.
Date of the incident: 02/22/00; Vessel name and/or identification
number: Adrien Rose, D538410; Type of vessel: Fishing; Vessel length:
46; Number of injuries: 0; Value of the damage reported: 0; Value of
the damage in constant 1997 dollars: 0.
Date of the incident: 02/20/01; Vessel name and/or identification
number: Snoopy II, D563195; Type of vessel: Fishing; Vessel length: 52;
Number of injuries: 0; Value of the damage reported: $500; Value of the
damage in constant 1997 dollars: $467.
Date of the incident: 05/30/01; Vessel name and/or identification
number: C-Venture, D539167; Type of vessel: Fishing; Vessel length: 73;
Number of injuries: 0; Value of the damage reported: $1,500; Value of
the damage in constant 1997 dollars: $1,400.
Date of the incident: Total; Average loss per year (15 years); Value of
the damage reported: $6,642,300; $301,923; Value of the damage in
constant 1997 dollars: $7,842,969; $356,499.
Date of the incident: Total for 10 fishing vessels 55‘ and over;
Average loss per year (15 years); Value of the damage reported:
$20,800; $1,387; Value of the damage in constant 1997 dollars: $25,146;
$1,676.
Source: Electronic marine casualty reports from the Data Administration
Division, U.S. Coast Guard.
[End of table]
Finally, the Corps‘ analysis assessed damages to trawlers only and
excluded potential damages to other vessels. Our analysis of Coast
Guard records on reported incidents for all vessels from 1986 through
2001 showed that conditions in Oregon Inlet caused damages totaling
about $7.8 million, or about $520,000 per year over that 15-year
period, which is 25 percent more than the Corps estimate of $392,000
per year in annualized:
benefits.[Footnote 35] However, most of the total damages--$7.7
million--were attributable to one accident involving a dredge, which,
torn from its anchor by a storm, struck and caused the collapse of a
part of the bridge that spans Oregon Inlet. If the dredge accident were
removed from the calculation, the average damages over the 15-year
period would be about $12,000 per year, or nearly 98 percent less than
the Corps‘ estimate.
Although we could verify some of the earlier estimates of vessel losses
and damages and were able to provide more current data from a review of
accident reports, the extent to which past deaths and vessel losses and
damages might have been prevented by the Corps‘ proposed jetty project
is not known. Consequently, we did not revise the Corps‘ estimate of
benefits to include this more recent data.
Corps Did Not Clearly Explain How It Derived Its Estimate Of Lives That
Might Be Saved by the Proposed Jetty Project:
In addition to not incorporating the economic value of the lives that
might be saved by the proposed jetty project in its estimate of
benefits, the Corps did not clearly explain how it estimated that 14
lives might be saved over the 50-year life of the project. Corps‘
Wilmington District Office officials told us that they used their own
studies and the 1987 Kearney/Centaur report as the basis for estimating
that 14 lives might be saved by the project. The Kearney/Centaur report
identified that 20 lives were lost with an associated loss of 21
vessels in Oregon Inlet from 1961 through 1986. We attempted to get
data from the Corps that would document the 20 lost lives, but the
Corps had not retained the supporting documentation for the Kearney/
Centaur report. As a result, we asked the Coast Guard to provide any
accident reports that it had relative to the vessel losses and 20 lost
lives identified in the Kearney/Centaur report. The Coast Guard could
only provide information on nine of the lost vessels. Based on our
review of the nine cases, we found that the Kearney/Centaur report
excluded four deaths resulting from a 1977 vessel loss even though
information in the Coast Guard accident report implicated inlet
conditions in the loss. In addition, we found that one death included
in the Kearney/Centaur report did not occur in Oregon Inlet. Moreover,
based on our review of more current Coast Guard records from 1986
through 2001 (see table 6 above), we identified two deaths--one in 1996
and the other in 2001--that were attributable to inlet conditions. Both
of these accidents involved small recreational boats. Consequently,
based on our review, we found that at least six deaths were
attributable to conditions in Oregon Inlet over the
25-year period from 1977 through 2001, which is slightly less than the
Corps estimate over a comparable period. However, whether these
accidental deaths would have been prevented by the jetty project is
uncertain. As mentioned above, the Corps‘ analysis assumed that all
prior vessel accidents that included deaths would be prevented by the
jetty project without clearly controlling for factors that would be
present with or without the jetty project. For example, Corps officials
told us that under some weather conditions the inlet would be hazardous
even with the recommended 20-foot channel and dual jetties in place.
Corps Relied on Outdated Data Collected with Questionable Survey and
Sampling Techniques to Estimate Recreational Benefits:
The Corps estimated that the jetty project alternative would generate
about $3.4 million dollars in annualized benefits for recreational
boaters by reducing high waves and sand accumulation in the ocean bar
navigation channel, thus allowing for more trips. This estimate
includes an estimated $2.8 million in benefits for private recreational
boats, with the remaining benefits for anglers on charter and party
boats. We could not verify the Corps‘ estimates because it did not
retain supporting documentation, and independently calculating the
estimates would require an inordinate amount of time and resources.
However, based on our review of the Corps‘ approach and methodology
used in developing the estimates, we have identified three limitations
that raise questions about the reliability and usefulness of the
estimated benefits.
First, the Corps‘ original data collection effort, conducted in 1983,
used a survey instrument that may have biased the boaters‘ responses in
favor of the jetty project. For example, to estimate the additional
trips that private recreational boaters might be willing to take if the
jetty project were constructed, the Corps mailed a survey to 3,876
registered owners of recreational power and sail boats at least 19 feet
long who were likely to have used Oregon Inlet in 1983. The Corps
received 1,044 usable responses[Footnote 36] and from them concluded
that private recreational boaters would increase their average annual
use of the inlet from 8.59 trips through the Inlet per year to 19.34
trips per year if the jetties were built. The cover letter accompanying
the mail survey included the following introduction to the topic,
stating that ’despite 22 years of intensive maintenance dredging, the
Corps has been able to maintain the channel depth only 25 percent of
the time and has never been able to maintain the 400-foot channel
width“ and that ’numerous groundings, vessel losses, personal injuries,
and deaths have occurred.“ In addition, the survey instrument asked
respondents to estimate the number of days per year they ’currently
use“ Oregon Inlet and the number of days per year they ’would use
Oregon Inlet if it were stabilized with dual jetties and a deeper, more
reliable channel.“ The wording implied that the channel would be safely
passable all of the time if the jetty project were built, which is not
the case. Corps officials acknowledge that even with the jetty project
there will be periods when weather conditions will make the inlet
impassable.
Concerning the estimated use of the inlet, a 1987 consultant‘s report
noted that some survey responses seemed too extreme to be credible. For
example, on average, respondents indicated they currently used the
inlet 11 days each year. However, a number of respondents indicated a
substantially higher use, with the highest reported estimate being 250
days per year. To address this concern in its most recent economic
analysis, the Corps calculated new estimates using only responses that
indicated a use of 60 days or less. This resulted in the Corps
excluding 23 responses that were above this number. However, the 60-day
threshold was arbitrary, and it neither accounts for the possibility
that some responses above the threshold may be legitimate nor addresses
the problem that responses below the threshold may have also been
subject to biased wording. While the overall estimated benefits are
lower than they would be if all responses were included, we could not
determine the reasonableness of these estimates. The Corps does not
believe the surveys contained bias. They said that the Office of
Management and Budget (OMB) approved the surveys and that the wording
’deeper, more reliable channel“ would be an accurate description of the
channel with the implementation of the jetty project. Both the
Paperwork Reduction Act and OMB‘s process for reviewing surveys have
changed since 1983. However, the OMB official who currently reviews
Corps surveys told us that the current OMB approval process does not
ensure that a survey instrument is free from bias, although the
reviewer may suggest changes if he or she detects bias, along with any
other editorial comments. Because OMB does not keep records beyond 10
years, we could not determine the nature and extent of OMB‘s comments
concerning the Corps‘ 1983 surveys.
Second, the Corps‘ 2001 economic analysis of recreational benefits
relied on survey data from 1983 and 1984. These data are outdated and
may not reflect the economic value that today‘s boaters would place on
any additional trips they would be able to take if the jetty project
were built. The demand for recreational fishing is dependent upon
factors such as the current cost (for example, expenses and time
incurred in traveling to the site) and the current availability of
substitute fishing sites and other recreational
opportunities.[Footnote 37] For its most recent analysis, the Corps
updated the original survey data by increasing the results by the rate
of growth in regional tourism and visitation from 1984 through 1995.
The Corps then used the updated survey data as a starting point for
projecting recreational demand another 50 years into the future--the
life of the jetty project--to 2051. However, changes in tourism and
visitation primarily reflect changes in population rather than changes
in relative prices or substitute recreational opportunities.
Consequently, the reliability of the Corps‘ recreational demand
projections is questionable. Corps officials acknowledged that their
recreational benefit estimates are based on outdated data but said they
had not received funding to update the data. In addition, they believe
that recreational activity has increased at Oregon Inlet and that using
data that are more current would not change estimated recreational
benefits of the jetty project. Nonetheless, the Corps does not have
current data on the economic value that recreational boaters would
attribute to the jetty project alternative to support its contention.
Third, in estimating the economic value of the additional fishing
trips, the Corps used data collected from anglers on private boats and
charter boats during three 1-week periods in August, September, and
October of 1983. The Corps used these data to estimate that the average
value of a fishing trip was $22.56 per person per day. However, both
the number of fishing trips and the type of catch vary considerably
over the year. The 3-month period during which the data were collected
is the highest-use period for recreational fishing. The value of a
fishing trip, according to those fishing in August, September, and
October, may differ from the value assigned by those fishing during
other months because the number of boats and anglers varies by season,
as does the type of fish caught and the severity of weather and sand
accumulation in the inlet. Therefore, since data were gathered only
from anglers during the peak recreational season, the Corps‘ estimate
of the value of a fishing trip may not be a reasonable representation
of the value of such a trip for the entire fishing season. Furthermore,
there was no update of these data in the Corps‘ most recent economic
analysis. Corps officials said that since most fishing trips occur
during the months of August, September, and October, values for those
months would be weighted most heavily, even if data from additional
months were collected, and that there was no reason to believe that
trips in other months would be less valuable. For example, they said
charter boat fishing rates are the same in other months as they are in
the highest-use months. Nonetheless, the Corps did not incorporate the
value of the additional trips that recreational anglers fishing in
lower-use months might be willing to take if the proposed jetty project
were built. The value of the additional trips during lower-use months
could be lower or higher than the value in higher-use months for
several reasons, including the type of fish that are available, the
weather, and the particular preferences of the angler.
Corps‘ Approach to Valuing Benefits Associated with Reduced Erosion Is
Inconsistent with Federal Guidelines:
The Corps estimated that the proposed jetty project would yield about
$1 million in annualized benefits by preventing the erosion of beaches
to the north and south of Oregon Inlet. Because the protected land to
the north of the inlet is part of the national seashore and to the
south of the inlet is part of a national wildlife refuge, the benefits
derived from the jetty project would be the recreational opportunities
generated from the public use of the protected land. However, the Corps
used valuation techniques that are not consistent with federal
guidelines for valuing recreational benefits. As a result, the
reliability of the Corps‘ estimate of $1 million for erosion prevention
is questionable and thus less useful because it does not reflect the
value of the land as it is currently used for recreation and as
wildlife habitat.
Federal guidance states that benefits arising from a project that
generates recreational opportunities should be measured in terms of the
willingness of users to pay for the recreational opportunity. For
example, the fees users are willing to pay to visit a site and any
unpaid value[Footnote 38] enjoyed by the recreationist can be used to
measure benefits. Although the Corps‘ economic analysis states that the
protected land could be valued in terms of its use for recreation, the
Corps chose not to do so because an earlier consultant‘s
report[Footnote 39] found drawbacks with an approach that based the
value of the land on the willingness to pay for recreational
opportunities. In particular, the consultant‘s report states that the
land has a ’uniqueness value“ to the nation that would not be captured
by techniques based on recreational visitation. As a result, the Corps
did not use willingness to pay for recreational opportunities to
calculate the value of the land. However, although the Corps agreed
with the consultant‘s argument, neither of the two valuation methods
used by the Corps measured the uniqueness value of the land.[Footnote
40]
The Corps used two different methods to derive two separate estimates
of the benefits associated with the land that would be ’protected“ by
the jetty project. Under one method, the Corps assumed that the jetty
project would protect 5 acres of land per year from natural erosion. To
determine the benefits, the Corps used the per-acre cost of bypassing
sand (about $200,000) instead of the land‘s value for recreational use.
This method is inconsistent with federal guidelines, because the cost
of preventing the erosion does not reflect willingness to pay for
recreational use of the land. As a result, we could not determine
whether the Corps‘ estimate overstates or understates the value of the
land for recreational use.
Under the second method, the Corps assumed that the jetty project would
prevent erosion of 9.5 acres from nearby beaches each year, or roughly
twice as much land as would be protected under the first method.
District officials said they used the market value of local, private,
undeveloped, non-erodible, oceanfront property as a way to reflect the
land‘s opportunity cost--the value of the land in its alternative best
use--to initially value the protected land at about $426,000 per acre.
However, because the protected land is erodible, the Corps reduced that
value by 75 percent to make the land worth about $107,000 per acre.
Under this method, the total value of the protected land was estimated
to be roughly $1 million. However, Corps officials did not have
documentation supporting the basis for reducing the value of the
protected land by 75 percent. Moreover, since the land being protected
is public land, it is not likely that the land will be sold for private
use. Further, this approach does not consider the land‘s use for
recreation and is, therefore, inconsistent with federal guidelines for
estimating recreational benefits. As a result, it fails to provide
decision makers with reliable information regarding these potential
benefits.
Corps officials said that their guidelines for conducting economic
analysis allow the benefits of environmental protection projects to be
judged equal to their costs, which is why the Corps used the cost of
bypassing sand as the value of the land. Nonetheless, as mentioned
above, the cost the Corps derived is not based on a measure of the
willingness to pay, and, as a result, the extent to which the Corps‘
estimated benefits approximate the value of the land for recreation
purposes is not known.
The Corps Did Not Account for Risk and Uncertainty Associated with All
Key Variables:
In developing its estimate of the benefits and costs of the jetty
project alternative, the Corps did not fully account for the extent to
which the net benefit estimates would be affected by the risk and
uncertainty associated with potential measurement errors and
variability in the underlying data and assumptions.[Footnote 41]
The economic analysis did account for some risk and uncertainty for
some variables. For example, in developing its estimate of the
operating costs that trawlers would save in harvesting fish if the
jetty project were built, the Corps adjusted its estimates to reflect
the year-to-year variability in fish populations. In addition, in
developing its estimate of the cost to construct the jetty project and
operate the sand bypassing system, the Corps increased its estimate by
about 15 percent to account for unforeseen events that might increase
construction costs. The Corps also included additional costs for sand
bypassing to ensure that neighboring beaches do not erode at a greater
rate than anticipated.
However, the Corps did not assess the effect of risk and uncertainty
for other key data and assumptions on the net benefit estimates. For
example, the Corps used single or ’point“ estimates for the amount of
sand estimated to pass over the weir; the trips and operating cost
savings for commercial fishing vessels; the additional trips that
recreational boaters might take; the extent to which the jetty project
might prevent vessel losses, damages, and accidental deaths; and the
amount of dredging that might be required in the interior channels even
with the proposed jetty project in place. For example, the amount of
sand that is expected to pass over the weir and be used to reduce
erosion on neighboring beaches is subject to some uncertainty because
of errors inherent in modeling sand transport as well as variability in
the frequency of storms and in ocean currents. By not fully assessing
the effect of uncertainty, a decision maker might not be aware of the
extent to which the net benefit estimates might change if the
underlying assumptions deviate from the values assumed by the Corps.
[End of section]
Appendix V: Comparison of the Proposed Oregon Inlet Jetty Project to
Similar Completed Jetty Projects:
Table 8 compares key characteristics of the proposed Oregon Inlet jetty
project to other similar jetty projects located on coastal inlets of
the Atlantic Ocean and Gulf Coast of the United States.
Table 8: Key Characteristics of the Proposed Oregon Inlet Jetty Project
and Similar Completed Jetty Projects:
Key Characteristics:: Number of jetties; Proposed for Oregon Inlet, NC:
2; Murrells Inlet, SC: 2; Colorado River, TX: 2; Ponce DeLeon, FL: 2;
St. Lucie, FL: 2; Perdido Pass, AL: 2; East Pass, FL: 2; Rudee, VA: 2;
Masonboro, NC: 2.
Key Characteristics:: Location of first jetty; Proposed for Oregon
Inlet, NC: North side of inlet; Murrells Inlet, SC: North side of
inlet; Colorado River, TX: East side of inlet; Ponce DeLeon, FL: North
side of inlet; St. Lucie, FL: North side of inlet; Perdido Pass, AL:
East side of inlet; East Pass, FL: East side of inlet; Rudee, VA: North
side of inlet; Masonboro, NC: North side of inlet.
Key Characteristics:: Year completed; Proposed for Oregon Inlet, NC:
Proposed; Murrells Inlet, SC: 1979; Colorado River, TX: 1990; Ponce
DeLeon, FL: 1971; St. Lucie, FL: 1982; Perdido Pass, AL: 1969; East
Pass, FL: 1969; Rudee, VA: 1968; Masonboro, NC: 1966.
Key Characteristics:: Length in feet; Proposed for Oregon Inlet, NC:
10,020; Murrells Inlet, SC: 3,455; Colorado River, TX: 3,500; Ponce
DeLeon, FL: 4,200; St. Lucie, FL: 3,975; Perdido Pass, AL: 1,800; East
Pass, FL: 1,220; Rudee, VA: 765; Masonboro, NC: 3,650.
Key Characteristics:: Location of second jetty; Proposed for Oregon
Inlet, NC: South side of inlet; Murrells Inlet, SC: South side of
inlet; Colorado River, TX: West side of inlet; Ponce DeLeon, FL: South
side of inlet; St. Lucie, FL: South side of inlet; Perdido Pass, AL:
West side of inlet; East Pass, FL: West side of inlet; Rudee, VA: South
side of inlet; Masonboro, NC: South side of inlet.
Key Characteristics:: Year completed; Proposed for Oregon Inlet, NC:
Proposed; Murrells Inlet, SC: 1980; Colorado River, TX: 1990; Ponce
DeLeon, FL: 1969; St. Lucie, FL: 1982; Perdido Pass, AL: 1969; East
Pass, FL: 1969; Rudee, VA: 1968; Masonboro, NC: 1980.
Key Characteristics:: Length in feet; Proposed for Oregon Inlet, NC:
6,575; Murrells Inlet, SC: 3,319; Colorado River, TX: 2,900; Ponce
DeLeon, FL: 2,700; St. Lucie, FL: 1,000; Perdido Pass, AL: 1,800; East
Pass, FL: 3,400; Rudee, VA: 815; Masonboro, NC: 3,450.
Key Characteristics:: Typical tidal prism[A] (in millions of cubic
feet); Proposed for Oregon Inlet, NC: 2,810.0; Murrells Inlet, SC:
580.0; Colorado River, TX: 1.7; Ponce DeLeon, FL: 509.0; St. Lucie, FL:
5.2; Perdido Pass, AL: 435.6; East Pass, FL: 1,620.0; Rudee, VA: 16.6;
Masonboro, NC: 680.0.
Key Characteristics:: Sediment transport, in cubic yards, as viewed
from land.
Key Characteristics:: Left; Proposed for Oregon Inlet, NC: 611,000;
Murrells Inlet, SC: 54,000; Colorado River, TX: 0; Ponce DeLeon, FL:
348,000; St. Lucie, FL: 72,600; Perdido Pass, AL: 130,000; East Pass,
FL: 65,000; Rudee, VA: 378,000; Masonboro, NC: 200,000.
Key Characteristics:: Right; Proposed for Oregon Inlet, NC: 1,473,000;
Murrells Inlet, SC: 186,000; Colorado River, TX: 600,000; Ponce DeLeon,
FL: 363,000; St. Lucie, FL: 130,000; Perdido Pass, AL: 65,000; East
Pass, FL: 130,000; Rudee, VA: 93,000; Masonboro, NC: 500,000.
Key Characteristics:: Net; Proposed for Oregon Inlet, NC: 862,000;
Murrells Inlet, SC: 132,000; Colorado River, TX: 600,000; Ponce DeLeon,
FL: 15,000; St. Lucie, FL: 57,400; Perdido Pass, AL: 65,000; East Pass,
FL: 65,000; Rudee, VA: 285,000; Masonboro, NC: 300,000.
Key Characteristics:: Weir location; Proposed for Oregon Inlet, NC:
North jetty; Murrells Inlet, SC: North jetty; Colorado River, TX: East
jetty; Ponce DeLeon, FL: North jetty; St. Lucie, FL: North jetty;
Perdido Pass, AL: East jetty; East Pass, FL: West jetty; Rudee, VA:
South jetty; Masonboro, NC: North jetty.
Key Characteristics:: Weir length in feet; Proposed for Oregon Inlet,
NC: 1,000; Murrells Inlet, SC: 1,880; Colorado River, TX: 1,000; Ponce
DeLeon, FL: Formerly 1,800; St. Lucie, FL: 900; Perdido Pass, AL:
1,000; East Pass, FL: Formerly 1,000; Rudee, VA: 475; Masonboro, NC:
1,000.
Key Characteristics:: Weir elevation in feet above mean low water;
Proposed for Oregon Inlet, NC: 1.5; Murrells Inlet, SC: 2.2; Colorado
River, TX: 0.74; Ponce DeLeon, FL: Closed; St. Lucie, FL: 0; Perdido
Pass, AL: -0.5; East Pass, FL: Closed; Rudee, VA: 2.15; Masonboro, NC:
2.16.
Key Characteristics:: Left; Proposed for Oregon Inlet, NC: 611,000;
Murrells Inlet, SC: 54,000; Colorado River, TX: 0; Ponce DeLeon, FL:
348,000; St. Lucie, FL: 72,600; Perdido Pass, AL: 130,000; East Pass,
FL: 65,000; Rudee, VA: 378,000; Masonboro, NC: 200,000.
Key Characteristics:: Right; Proposed for Oregon Inlet, NC: 1,473,000;
Murrells Inlet, SC: 186,000; Colorado River, TX: 600,000; Ponce DeLeon,
FL: 363,000; St. Lucie, FL: 130,000; Perdido Pass, AL: 65,000; East
Pass, FL: 130,000; Rudee, VA: 93,000; Masonboro, NC: 500,000.
Key Characteristics:: After jetties, percentage of time channel less
than authorized depth; Proposed for Oregon Inlet, NC: NA; Murrells
Inlet, SC: 1; Colorado River, TX: 70; Ponce DeLeon, FL: 10 or less; St.
Lucie, FL: 80; Perdido Pass, AL: 0; East Pass, FL: 20; Rudee, VA: 7 to
8; Masonboro, NC: Less than 5.
[A] Tidal prism is the volume of water flowing in or out of an estuary
between high and low tides.
Source: GAO interviews with officials responsible for the projects.
[End of section]
Appendix VI: Comments from the Department of the Army:
DEPARTMENT OF THE ARMY OFFICE OF THE ASSISTANT SECRETARY CIVIL WORKS
108 ARMY PENTAGON:
WASHINGTON DC 20310-0108:
13 September 2002:
REPLY TO ATTENTION OF:
Mrs. Gary L. Jones Director:
Natural Resources and Environment U.S. General Accounting Office:
441 G Street, NW Washington, D. C. 20548:
Dear Mrs. Jones:
This is the Department of Defense (DoD) response to the General
Accounting Office (GAO) draft report, GAO-02-803, OREGON INLET JETTY
PROJECT: Environment and Economic Concerns Still Need to be Resolved,
dated August 28, 2002, (GAO Code 360049).
We appreciate the opportunity to comment on GAO‘s draft report as well
as GAO‘s cooperation in the clarification of issues by the Army. The
report is important to the Department because it provides a current and
independent assessment of the Oregon Inlet jetty project. It is
responsive to the issues you were charged to address, specifically, (1)
assess Federal efforts to maintain the ocean bar navigation channel in
Oregon Inlet; (2) assess the extent to which the Corps 2001 economic
analysis of the jetty project is useful for decision making; (3)
provide information on the performance of similar jetty projects; (4)
determine whether the Corps applied lessons learned from similar jetty
projects in its design of the Oregon Inlet jetty project; and (5)
identify and discuss concerns raised by the Departments of Commerce and
Interior about development of the jetty project. Our comments are
ordered to address these five topics.
(1) The GAO report accurately assesses Federal efforts to maintain a
reliable navigation channel. We concur in the GAO finding that because
of the inlet‘s high-energy environment, dredging efforts have not
provided a safe navigation channel and consequently loss of life,
vessel losses, and vessel damages will likely continue. It is also
likely that the Coast Guard will continue to have difficulty
maintaining navigation buoys. The average cost of dredging to maintain
a 14-foot navigation channel from 1983-1994 was $4.1 million per year,
but this provided a reliable channel only 23 percent of the time. After
1994, the Corps spent about $2 million per year and maintained the
channel depth about 15 percent of the time. Dredging has simply not
been a reliable means of maintaining a safe channel.
(2) We believe that some differences in benefits result from
differences in methodologies employed by the two agencies and a GAO
auditing perspective versus a Corps project evaluation perspective.
Since the Corps has not done any economic studies since 1999, it is
difficult to evaluate GAO data that differs from data in the Corps
study. Overall, the Corps agrees with GAO‘s conclusions and
recommendations that GAO was unable to determine whether the proposed
jetty system is economically justified at this time and that a new
economic analysis of the project is needed to decide whether to proceed
with the project. While GAO was unable to assess the effects of all the
changes to net benefits, GAO‘s conclusions appear to be reasonable.
Given the date of the Corps‘ most recent economic analysis of the jetty
project, the Corps‘ own regulations require an economic reanalysis
before starting construction.
(3) and (4) The GAO report provides information on similar jetty
projects, such as those constructed with dual jetties and a low weir
section. We concur in the GAO findings that the Corps applied lessons
learned from construction of similar jetty projects and from internal
Corps guidance. Masonboro Inlet in particular, which is located in the
Wilmington District area and has performed as planned, provided
valuable information on the need for dual jetties, the proper weir
length, and the effect of erosion in this area. Finally, we concur that
the information on eight similar jetty projects, their limitations, and
the reasons for those limitations was useful. The information is
helpful in maintaining our confidence that the Oregon Inlet project has
adequate information on sand movement and should function as designed.
(5) The discussion of concerns of environmental resource agencies
repeats concerns raised to the Feasibility Report, the Final
Environmental Impact Statement, and in the referral to the Council on
Environmental Quality (CEQ). Since the GAO report does not fully
present the Corps position, we are enclosing the CEQ response package
that addresses these issues for the record. We are especially pleased
that GAO concurs with our recommendation that it would not be prudent
to expend additional public funds to accomplish an economic reanalysis
until CEQ favorably resolves the environmental concerns regarding the
proposed jetty project and there are assurances from the Department of
the Interior that permits will be granted. Despite 35 years of
extensive studies, this project continues to show no progress, because
of the environmental concerns and the reluctance of the Department of
the Interior to provide approval for use of its lands to anchor any
jetties. The Corps continues to believe that it has made project design
changes and taken adequate mitigation measures to accommodate the
environmental concerns of the Departments of Interior and Commerce. The
Corps also believes that the jetty project is needed to allow large
trawlers to navigate the inlet safely. We await CEQ‘s findings on the
environmental issues for this potential project.
Sincerely,
R. L. Brownlee Acting Assistant Secretary of the Army (Civil Works):
Signed by R. L. Brownlee:
[End of Section]
Appendix VII: Comments from the Department of the Interior:
United States Department of the Interior:
OFFICE OF THE SECRETARY Washington, D.C. 20240:
SEP 18 2002:
Ms. Gary L. Jones:
Director, Natural Resources and Environment U.S. General Accounting
Office:
441 G Street, N.W. Washington, D.C. 20548:
Dear Ms. Jones:
Thank you for providing the Department of the Interior the opportunity
to review and comment on the Draft Report entitled ’OREGON INLET JETTY
PROJECT: Environmental and Economic Concerns Still Need to Be Resolved“
(GAO-02-803) dated August 28, 2002. In general, we agree with the
findings in the report. The report is an objective and thorough
analysis of a complicated project with over three decades of
development. In particular, we concur with the finding that an analysis
of incremental channel depths to update the most economically
beneficial channel depth is warranted. The current commercial and
recreational fishing fleets differ from those used in the original
economic analyses for the project, and the project economics should
accurately reflect the needs of the vessels currently using the inlet.
We also agree with the recommendations that are directed to the Army
Corps of Engineers, as they are consistent with Departmental position
and comments over the past 10 years.
Although we concur with the findings of the draft report, we would like
to offer a few points of clarification. The enclosure provides specific
comments from the U.S. Fish and Wildlife Service and the National Park
Service. We hope our comments will assist you in preparing the final
report.
Sincerely,
Assistant Secretary for Fish and Wildlife and Parks:
Signed by the Assistant Secretary for Fish and Wildlife and Parks:
Enclosure:
U.S. General Accounting Office Draft Report ’OREGON INLET JETTY
PROJECT: Environmental and Economic Concerns Still Need to Be Resolved“
GAO-02-803:
SPECIFIC COMMENTS:
The report‘s statements concerning the U.S. Army Corps of Engineers‘
current position are inconsistent. On one hand, the draft report states
that the Corps is currently unwilling to spend additional public
resources on analysis of the jetty project (see page 9, paragraph 2;
page 47, paragraph 2; and page 48, paragraph 1). On the other hand, the
report describes the Corps as currently unwilling to spend additional
public resources on analysis of alternatives for improving the safety
and navigability of Oregon Inlet (see page 46, paragraph 2). The latter
statement is much broader than those on pages 9, 47, and 48. Since the
focus of this report is the jetty project rather than the overall
management of Oregon Inlet, we suggest that the statement on page 46
should be modified to be consistent with the others and address only
the jetty project. We further suggest that the second paragraph on page
46 should note that the Corps has not applied for Interior permits to
construct the current dual jetty system.
The draft report notes that economic benefits may result from avoided
accidental deaths at the proposed jettied inlet (see page 7, paragraph
1; and page 29, paragraphs 1 and 2). While we concur that this factor
was not included in the current economic justification for the proposed
project, we note that the economic costs of potential increases in
accidental deaths, vessel damage, and other injuries resulting from the
dual jetty and sand bypassing system are not incorporated either. The
report should recommend that any further analysis of this project
should include both the potential benefits and the increased risks to
human life and vessel safety resulting from the jetties.
It would also be helpful if the report included a definition of the
terms ’commercial vessel“ and ’recreational vessel,“ since the report
recommends that any further economic analysis of the project should be
based on commercial fishing trip data (see page 26, paragraph 1).
The current statement regarding Interior‘s concern of ’depositing too
much sand onto its land“ (see page 8, paragraph 2) does not adequately
summarize our concerns about the sand bypassing system. We recommend
that this statement be modified to read, ’Interior believes that the
jetties will increase beach erosion, especially on the south side of
the inlet, and that the project‘s sand bypassing system could harm
coastal habitat and wildlife by depositing large quantities of sand
annually without allowing sufficient time for recovery of the
ecosystem.“ Similarly, the last sentence on page 8 that continues on
page 9, would be more accurate if stated ’The weir is also intended to
facilitate the collection of sand, which the Corps plans to bypass to
beaches on the south side of the inlet to address erosion and
interrupted sediment transport.“:
The draft report states that the National Park Service manages the
Federal lands located on the north side of Oregon Inlet (see page 8,
paragraph 2; and page 41, paragraph 1). The NPS requests that these
statements be expanded to clarify that Pea Island National Wildlife
Refuge and lands south of the Refuge, which would be affected by
project-
caused erosion and perpetual sand placements, are likewise within the
boundaries of Cape Hatteras National Seashore.
The report would more accurately describe the purpose of the terminal
groin on PINWR if it stated that, ’The terminal groin is a rock
structure that was completed in 1991 to protect the southern end of the
Bonner Bridge“ (see page 16, paragraph 2). Additionally, we suggest
that the report recommend that any further economic analysis of the
jetty project should take into account the anticipated expiration of
the right-of-way permit for the terminal groin in 2010, possible
removal of the terminal groin, and resulting increased costs of the
jetty project. Also in this paragraph, we recommend replacing
’adjacent“ with ’downdrift“ in the second to last sentence.
Interior does not agree that the Masonboro Inlet jetties should be
considered ’performing as planned“ (see pages 31 through 34). The
original project design utilized one jetty, constructed in 1966. In
1980, however, a second jetty was added to improve the performance of
the managed inlet. Erosion of adjacent shorelines on Masonboro Island
has also led to unanticipated supplemental dredging and beach fill
activities to offset the interrupted sediment supply on Masonboro
Island. Using one parameter to evaluate the overall performance of weir
jetty projects, whether actual dredging needs are comparable to
original project specifications, does not fully reflect the success or
failure of those projects. We recommend that although Masonboro Inlet
provides valuable lessons about weir jetties, the report should not
characterize it as ’performing as planned.“ Further, we urge caution in
making any direct comparison of the processes at Masonboro and Oregon
Inlets since Masonboro Inlet experiences only one third of the sediment
transport (see page 19, paragraph 1) and a lower wave energy climate
than Oregon Inlet.
There are a few points worth clarifying in the section on pages 41
through 43 that itemize Interior‘s concerns with the project. In the
first bulleted concern, the second and third sentences would be
improved by reading ’Interior stated that if the jetties are built,
erosion and accretion patterns will be modified both south and north of
the inlet, which in turn will increase overwash of the islands,
especially during storms. This overwash will harm valuable wildlife
habitat as well as plants and vegetation that provide food for
waterfowl and other migratory birds.“ The next sentence should replace
the word ’would“ with ’could“ due to high levels of uncertainty
regarding specific sediment transport volumes. We also recommend
deletion of the phrase ’the Bonner Bridge and“ from the following
sentence.
In the first bulleted point on page 42, we recommend that the 3‘
sentence be amended to read ’Interior stated that over the years
frequent sand bypassing of large volumes might permanently eliminate
these food sources and produce severe long-term adverse impacts on
breeding, migrating and overwintering shorebirds.“ The latter part of
that sentence can serve as an independent statement starting with
’Among these birds are the Great Lakes piping plover ...“. The last
sentence of the bulleted point would be more accurate with the phrase
’of incompatible sands“ inserted after ’perpetual sand placements.“:
The second bullet on page 42 describes Interior‘s concerns about the
performance of the weir. In particular, we remain concerned about the
likely impacts of the Dare County Beaches Storm Damage Reduction
Project, a large beach nourishment project immediately north of the
Oregon Inlet jetties project area. While the draft report summarizes
these concerns, the fifth sentence inaccurately attributes our concern
over reduced sediment supply to aquatic habitats within Pamlico Sound
to the offshore sand mining proposed for the beach nourishment project.
In fact, the construction of the jetties and associated dredging and
sand bypassing are the cause of our concern about reduced sediment
supply to estuarine habitats, not the offshore sand mining. We
recommend that this statement be moved to its own bullet as a separate
Interior concern related to the jetties, separate from the Dare County
beach nourishment project.
The NPS believes that the first complete bulleted point on page 43 does
not fully describe the impact of the jetty project on public recreation
at the Seashore. NPS therefore requests the addition of the following
clause to the first sentence of this bullet point, ’contrary to one of
the legislated purposes of Cape Hatteras National Seashore.“:
The last sentence summarizing Interior‘s concerns (pages 43 and 44)
should be modified to more accurately describe the purpose of the PINWR
by ending with the phrase ’to manage, protect, and restore migratory
birds and other wildlife.“:
We request several clarifications in the last paragraph on page 46
before the Conclusions section. The fifth sentence would be more
accurate if it read ’FWS, likewise, issued the Corps a special use
permit for disposal of dredge material on refuge lands during the
Corps‘ 2002 dredging effort.“ The next sentence contains a
typographical error, incorrectly referring to the Pea Island National
Wildlife Reserve instead of the Pea Island National Wildlife Refuge. We
recommend replacing the first two words (’FWS said“) at the start of
the seventh sentence with the phrase:
’According to the NPS special use permit, the dredging operation....“:
[End of Section]
Appendix VIII: Comments from the Department of Commerce:
UNITED STATES DEPARTMENT OF COMMERCE National Oceanic and Atmospheric
Administration CHIEF FINANCIAL OFFICER/CHIEF ADMINISTRATIVE OFFICER:
SEP 17 2002:
Ms. Gary Jones:
Director, Natural Resources and Environment:
United States General Accounting Office 441 G Street, N.W.
Washington, DC 20548:
Dear Ms. Jones:
Enclosed is the National Oceanic and Atmospheric Administration‘s
response to the draft report OREGON INLET JETTY PROJECT: Environmental
and Economic Concerns Still Need to Be Resolved (GAO-02-803). We
appreciate the opportunity to provide comments.
Sincerely,
Sonya G. Stewart:
Signed by Sonya G. Stewart:
Enclosure:
General comments:
The Department of Commerce and the National Oceanic and Atmospheric
Administration (NOAA) commend the General Accounting Office‘s (GAO)
work in evaluating the issues surrounding the Oregon Inlet jetty
construction project. Overall, we find that the report is thorough, and
we concur with the determination that considerable revision of the
economic and other analyses are needed before the feasibility and
environmental effects of building jetties can be determined. We offer
the following comments to clarify our position on some issues.
Specific comments:
Pages 8-9 ’Results in brief‘ and page 40 ’Commerce and Interior remain
concerned the Oregon Inlet project will harm the environment“ The
report states that the U. S. Army Corps of Engineers (COE) utilized
lessons learned from other jetty projects by incorporating a weir into
the design of the northern jetty to allow fish larvae to enter the
sound. NOAA notes that the Corps originally found inclusion of a weir
to be not acceptable based on considerable evidence indicating that
such a structure could become blocked by sand. In such a situation, the
weir would cease to function as a possible avenue for larvae movement,
and also would cease to function as a sand bypass mechanism.
The concern about sand bypass is referenced as recently as 1995,
wherein the Wilmington District‘s Feature Design Memorandum for Sand
Bypassing Management states: ’The major concerns, particularly with the
weir jetty plan, were the high rates of littoral (sand) transport that
could occur during singular or multiple storm events, and the
possibility of reversals in the net direction of littoral transport
during any year. Also, the amount of material available for bypassing
would be limited to that retained in the sediment trap. With respect to
storms, sand transport could be so large that the weir would become
…landlocked,‘ thus preventing the deposition of material in the
sediment trap. . . ’ Considering the importance of successful weir
design and function, NOAA is extremely concerned over the uncertainties
associated with this key component of the project.
NOAA notes that no direct evidence exists demonstrating the
effectiveness of this or any other weir for achieving larval ingress.
With specific reference to the proposed Oregon Inlet jetties, NOAA has
advised the COE that the current weir design is unacceptable since it
may not be properly positioned to allow larval ingress. More
specifically, the proposed weir would be located adjacent to the
shoreline and would extend offshore, joining the main jetty at a water
depth of around 1 meter (m) below mean sea level (based on the adjusted
depth contours following filet formation at the north jetty). Mean
tidal ranges in the inlet are 0.6-0.7 m, thus, maximum water depths at
the seaward end of the weir would be approximately 2 m. Because species
composition, distribution, and abundance of larval fishes in such
shallow
water outside of inlets are largely undetermined, there is no basis for
the
presumption larvae will be transported across the weir.
Larval transport through the inlet is no minor issue. For numerous
species born in offshore waters of the Atlantic Ocean, it is essential
that they successfully migrate inshore from these offshore locations,
through coastal inlets, and into estuaries where growth and development
are possible. They cannot survive and mature in the open ocean. This
group includes such notable species as summer flounder, shrimp, spot,
and Atlantic croaker. Summer flounder is a key target species of
commercial fishers for which the jetty project is intended to aid.
Oregon Inlet, due to its location, is a key entrance way to Albemarle
Sound, Roanoke Sound, and northern Pamlico Sound for planktonic larval
fish and invertebrates seeking essential developmental grounds in
estuarine waters. The inlet, in many respects, is a last chance at
survival for these organisms, since there is little probability that
they would survive the journey to other coastal inlets located to the
north and south of Oregon Inlet. Any reduction in the number of larvae
that migrate through Oregon Inlet and into Albemarle Sound would not be
offset by those entering from other inlets, since the hydrological
connection between Albemarle Sound and other inlets is only minor.
Also, according to North Carolina State University professor Dr. John
Miller, Albemarle Sound is under-colonized by larvae. It is therefore
likely that any reduction in larvae passed through Oregon Inlet would
result in a comparable reduction in fishery production and harvest.
With regard to Page 8 (’Results in brief‘), it should be noted that
NOAA, in addition to the U.S. Fish and Wildlife Service and the
National Park Service, is concerned that the jetties will significantly
alter sand movement in the vicinity of Oregon Inlet and damage beaches,
dunes, beds of submerged aquatic vegetation, salt marshes, shallow
water habitats, and other aquatic sites and resources. NOAA also raised
many or these concerns in referring the project to the President‘s
Council on Environmental Quality.
Pages 24-27: ’Corps‘ Economic analysis for the proposed Oregon Inlet
Jetty Project has several limitations that undermine its usefulness“
and pages 66-69: ’Corps analysis of benefits to commercial fishing
vessels relied on outdated trip data and excluded certain vessels“ NOAA
agrees with the GAO that using data from the 1980s to estimate
potential benefits results in unrealistic estimates. In support of
GAO‘s findings, we note that since the 1980s, the size of the
commercial fishing fleet has declined due to a vessel reduction program
implemented by the South Atlantic Fishery Management Council. For this
and other reasons, the foreseeable forecast for vessel numbers is one
of fewer vessels rather than more.
Pages 7 28-29 69, and 75: Vessel safety and loss of life The GAO report
appears to contain conflicting statements regarding inlet safety. Page
28 states, ’Corps estimates did not incorporate the economic value of
accidental deaths that might be prevented by the proposed project.“
This statement implies that the Corps‘ estimate of 14 lives saved
during 50 years is valid. However, on page 69 the report states the
’Corps‘ estimates of vessel losses and damages are based on unsupported
assumptions and outdated data.“:
NOAA places the utmost value on human life, and fully supports the goal
of safe and reliable navigation. However, we question the Corps‘
estimates (as does the GAO draft report). We also note that the Corps
did not assess the potential loss of life and related economic losses
resulting from the presence of jetties. Based on information we
examined, it is evident that jetties themselves may serve as a source
of injury and accidental death. NOAA recommends that GAO consider
revising these sections to address the potential dangers and economic
costs that jetties present, and to specify that these considerations
also require evaluation.
Page 32: ’Two proiects are currently performing as planned“ NOAA does
not agree that the Masonboro Inlet Project is generally performing as
planned. Although the GAO report (page 33) accurately describes the
many problems associated with the Masonboro Inlet Project, the overall
impression is that the jetties are operating as planned, which is
clearly not the case. An abbreviated list of problems includes:
* The original project design called for a single jetty with a weir, to
be located on the north side of the inlet. After currents undermined
the jetty, it was determined that a second jetty would be needed.
* Predicted sand accumulation in the designated sand accumulation basin
did not occur but instead, accumulated at the south end of Wrightsville
Beach, causing difficulties for vessels entering the inlet.
* Erosion on Masonboro Island, a National Estuarine Research Reserve,
and Wrightsville Beach, a high-use municipal beach, are at least
accentuated by the project since periodic sand bypassing involves use
of heavy equipment and causes considerable disturbance of human and
natural uses of the beach.
Additionally, it should be noted that unexpected problems such as those
realized at Masonboro Inlet could have far greater consequences at
Oregon Inlet where sand volumes, wave energy, and the tidal prism far
exceed those at Masonboro Inlet. Further, even though the dredging
frequency may be less than anticipated at Masonboro and Murrells
inlets, this is still reflective of miscalculation by the COE and
should not be regarded as expected or planned performance, even though
the outcome is beneficial in these instances.
Page 23: ’Oregon inlet‘s high energy environment and the Corns‘ limited
dredging have also reduced the Coast Guard‘s ability to properly mark
the ocean bar navigation channel“ NOAA is pleased to note that the GAO
addresses the current situation at Oregon Inlet relevant to placement
of channel markers (buoys) by the U.S. Coast Guard. Given the location
and natural conditions at this high energy inlet, it is likely that the
location and depth of navigable waters will remain variable with or
without jetties. However, as the GAO report implies, an improved
dredging program could improve the ability of the Coast Guard to mark
the channel, thereby improving navigation and safety at Oregon Inlet.
Page 15: Editorial comment Because it is describing a statutory
definition in this case, NOAA recommends capitalizing the term
’Essential Fish Habitat“ in paragraph two.
Page 40: Editorial comment To be consistent with the rest of this
section, NOAA suggests using bullets to separate the primary points in
this section, i.e., habitat impacts, larval migration, and the safety
record at Oregon Inlet.
Recommendations:
Page 48: GAO Recommendations NOAA supports the recommendations made by
the GAO in this report.
[End of section]
Appendix IX: GAO Contact and Staff Acknowledgments:
GAO Contact:
(Ms.) Gary L. Jones (202) 512-3841:
Staff Acknowledgments:
In addition, Tim Guinane, Roy Judy, Ken McDowell, Cynthia Norris, Anne
Rhodes-Kline, John Scott, Amy Webbink, and Jim Yeager made key
contributions to this report.
FOOTNOTES
[1] P.L. 81-516, the River and Harbor Act of 1950, authorized the
project, officially titled the Manteo (Shallowbag) Bay, North Carolina,
project.
[2] All dollars in this report are 1997 dollars unless otherwise noted.
[3] P.L. 91-611, River and Harbor and Flood Control Acts of 1970.
[4] A weir is a section of a jetty that is lower than the rest of the
structure. The weir is typically designed to allow water and sand to
flow over it when the water level is greater than low tide.
[5] ’The Outer Banks of North Carolina: Budget of Sediment and Inlet
Dynamics Along a Migrating Barrier System“ by Douglas L. Inman and
Robert Dolan, Journal of Coastal Research, Spring 1989,
Charlottesville, Virginia.
[6] The Herbert C. Bonner Bridge transverses Oregon Inlet and carries a
highway that connects Bodie Island on the north side of the inlet to
Pea Island on the south.
[7] Draft is the distance between the water level on a loaded vessel
and its keel (bottom). The channel depth is determined by the loaded
draft of a typical vessel as well as by factors including wave action
and the extent to which the vessel ’squats“ in the water when it is
underway due to propeller action.
[8] Identification of Essential Fish Habitat and requirements
concerning its coordination and management are contained in the
Magnuson-Stevens Fishery Conservation and Management Act, as amended by
the Sustainable Fisheries Act of 1996 (P.L. 104-297).
[9] The Corps calculates the percentage by periodically surveying the
depth of the channel. If any portion is less than the authorized depth
of 14 feet, the channel is considered unavailable.
[10] The Corps‘ estimate of sand movement is for the period 1956
through 1975 as presented in its September 2001 GDM on the jetty
project.
[11] A Reassessment of the Economic Feasibility of the Oregon Inlet
Project, Kearney/Centaur, a Division of A.T. Kearney, Inc., prepared
for the Corps of Engineers, July 1987.
[12] Data for 1999 through 2001 include landings made by both in-state
and out-of-state vessels to seafood dealers in Dare, Hyde, Pamlico, and
Beaufort Counties. According to state officials, trawlers using
specified gear that land ocean-caught fish in these counties are
assumed to pass through Oregon Inlet. Trips made by North Carolina
vessels to land fish in other states are not included. Data for smaller
vessels exclude fish that were landed in Hatteras (Dare County) because
these landings are assumed to have been made using Hatteras Inlet
[13] Under the North Carolina trip ticket program, which was begun in
1994, seafood dealers are required to report certain information about
commercial fish landings, including the landing vessel‘s
identification, the species of fish caught, and the type of fishing
gear used.
[14] The value of a statistical life is derived from studies of
individuals‘ willingness to pay for small reductions in the risk of
dying. The estimate represents the value of the reduction in risk to a
population and not the value of any identifiable individual.
[15] The $1.9 million represents the annualized amount, at 7.125
percent interest, of dredging costs during the 4-year period required
to construct the jetty project.
[16] The $6.8 million is the annualized value of the jetty project‘s
construction costs.
[17] The Corps made some computational errors in calculating the O&M
costs for the current dredging program. Specifically, the Corps
excluded $799,285 in costs that it had incurred dredging the ocean bar
navigation channel in 1990, which it had inadvertently identified as an
interior channel dredging expense. In addition, the Corps mistakenly
double-counted $876,472 of costs incurred in 1991 to dredge the ocean
bar navigation channel. We corrected for these two errors that
essentially offset each other. Corps officials agreed with this
correction.
[18] Even with the additional dredging, for one of the three projects
the channel has been available less than the expected amount of time.
[19] A spit is a narrow point of land or sand mass extending from the
shore.
[20] In 1992, the Secretary of the Interior issued two conditional
permits to the Corps for use of Interior lands for jetty construction
contingent on completion of project plans and environmental studies.
These conditional permits were rescinded in 1993.
[21] Pea Island National Wildlife Refuge is within the boundary of the
Cape Hatteras National Seashore.
[22] This panel was named for the first chairman, Dr. Douglas Inman, a
coastal oceanographer with the Scripps Institution of Oceanography.
[23] The terminal groin at Oregon Inlet is a rock structure built
perpendicular to the shoreline to protect the southern end of the
Bonner Bridge by preventing the erosion of land on Pea Island, into
which the bridge is anchored.
[24] Economic and Environmental Principles and Guidelines for Water and
Related Land Resources Implementation Studies, U.S. Water Resources
Council, 1983.
[25] Based on the state of North Carolina‘s commercial fish landings
trip ticket program.
[26] According to the state of North Carolina, the smaller vessels
averaged about 35 feet in length and trawlers averaged about 73 feet.
Vessels that are 35 feet in length have a draft of approximately 4 to 5
feet.
[27] Since the Corps assumes no change in the fish harvest, the
appropriate measure of savings is the marginal cost of the resources,
such as fuel and oil, which would be saved by the proposed project.
[28] We used the period 1999 through 2001 because state officials said
their vessel licensing data from before 1999 are less reliable. Vessel
licenses were used to identify the county out of which each vessel
operated in order to match the counties represented in the consultant‘s
1987 study. Nonetheless, regardless of the vessels‘ operating ports,
landings data by type of fishing gear also suggest trawler trips have
declined relative to the consultant‘s estimate from the mid-1980s. For
example, for landings made in Dare, Hyde, Pamlico, and Beaufort
Counties from 1994 through 1995, vessels using trawl gear landed about
9.3 million pounds of fish on 561 trips, while vessels using gill nets
landed about 16.3 million pounds of fish on about 5,200 trips
(including trips via Hatteras Inlet). Vessels using gill nets are
generally smaller than trawlers.
[29] For the adjusted analysis, we assumed no change in the fraction of
total trips forced to other inlets or ports or in the average length of
time a vessel is delayed. Using alternative values for these
assumptions would change the estimated benefits.
[30] The Kearney/Centaur report, cited earlier.
[31] 1990 Update of 1984 Economic Analysis: Manteo (Shallowbag) Bay
Project, North Carolina by the Corps of Engineers‘ Wilmington District,
July 1990.
[32] An Assessment of the Regional Economic Benefits of the Oregon
Inlet Stabilization Project by the Horizon Planning Group, Wilmington,
NC, January 1995.
[33] This calculation includes only the vessels listed as lost by the
Corps consultant that we could verify and vessels identified as lost in
our review of more recent Coast Guard records. Also, complete records
were not available on state registered recreational boat accidents to
determine how many were lost during the period we reviewed. The 1987
consultant apparently did not review such records when identifying
vessel losses.
[34] 1987 Kearney/Centaur study, cited earlier.
[35] Our estimate of damages is based on reported incidents and does
not include any damages that were not reported to the Coast Guard.
[36] In 1983, the Corps reported using 1,094 responses and a response
rate of 46 percent. In 2001, the Corps reported using 1,044 responses,
stating that 176 surveys were undeliverable and 681 others were
considered ’not usable.“ The Corps deemed a response ’not usable“ if
the respondent no longer owned a boat, the boat was not used in the
ocean, or because the information provided was ’invalid“ or appeared
duplicative. The 2001 General Design Memorandum does not project the
survey results to the entire population of respondents.
[37] The Corps used a ’travel cost“ model to estimate the value of the
additional trips. This is a technique for approximating the value that
recreationists would be willing to pay for the use of a site, based on
factors such as the expenses and value of the time required to travel
to the site.
[38] This unpaid value is called ’consumers‘ surplus“ and is a standard
measure of the net benefit derived from purchasing a good or service.
Since the protected land is publicly provided and no fees are charged
to enter the site, the value of the land can be estimated using
indirect means such as the travel cost model.
[39] The Kearney/Centaur report, cited earlier.
[40] Economic techniques that measure total economic value could assess
whether the acres saved would add to the uniqueness value of the
national seashore and the wildlife refuge (use and non-use values).
[41] Federal guidance for water resources planning states that the
effect of the risk and uncertainty should be examined. Risk reflects
situations where potential outcomes can be described using reasonably
well-known probability distributions. Uncertainty reflects situations
where potential outcomes cannot be described in objectively known
probability distributions.
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