Army Corps of Engineers

An Assessment of the Draft Environmental Impact Statement of the Lower Snake River Dams Gao ID: RCED-00-186 July 24, 2000

The precipitous decline of salmon has caused the National Marine Fisheries Service to list four different species of salmon and steelhead native to the Snake River as endangered or threatened under the Endangered Species Act. In 1995, the Army Corps of Engineers, which operates four hydroelectric dams on the Lower Snake River, began to study how to improve migration conditions for juvenile salmon. The Corps listed four alternatives: maintain current operations, breach the dams so that the water courses around them, increase transportation of juvenile salmon around the dams, or make improvements to the dams' systems for collecting juvenile salmon and barging or trucking them past the dams. Their draft environmental impact statement made no recommendations about which of the four alternatives to adopt. The net economic effect on electricity costs, some $245 million a year, is reasonable. Breaching the dams would mean losing hydroelectric power generated by the dams and would affect shipping on the Lower Snake River. Although the Corps' transportation analysis followed appropriate guidelines, it did not fully consider the effect of some of its assumptions and has not corrected some known errors. Also, breaching would affect air quality by increasing dust in the air and adding airborne pollutants from substitute sources of power and transportation. The Corps is now considering public and agency comments on the draft environmental impact statement before revising it.

GAO noted that: (1) the Corps generally adhered to the procedural requirements of the National Environmental Policy Act (NEPA), the Endangered Species Act (ESA), and other relevant guidelines in preparing the EIS; (2) as required by NEPA, the Corps coordinated with other federal agencies and affected stakeholders, obtained comments from other agencies and the public, and reported on the environmental impacts of proposed alternatives; (3) similarly, the Corps followed the procedural requirements of ESA, which required the Corps to consult with the National Marine Fisheries Service and the Fish and Wildlife Service; (4) the scope of the Corps' draft EIS is comprehensive, in that it considers a range of effects, including those on the environment, the economy, and wildlife; (5) while the Corps' actions in developing the EIS appear consistent with procedural requirements, the substance of the agency's analyses and conclusions has been challenged; (6) in GAO's view, the Corps' analysis and presentation of the effects of breaching on electricity costs is reasonable, however GAO could not determine the reasonableness of the Corps' estimated effects on transportation costs and air quality; (7) the net effect on electricity costs, estimated to be $245 million a year, has been reviewed by various stakeholders and subject matter experts, as well as by GAO, and found to be reasonable; (8) in the case of transportation costs, some concerns regarding the Corps' assumptions make the reasonableness of the transportation estimate to be uncertain; (9) for example, the Corps estimated that as much as $532 million in infrastructure would be needed for road, rail, and storage facilities if barge shipments were discontinued on the Snake River; (10) however, the Corps assumed that these infrastructure improvements would be made without affecting the transportation cost estimate; (11) the Corps did not sufficiently analyze the validity of this assumption or measure the sensitivity of the transportation estimate to this assumption; (12) likewise, the reasonableness of the Corp's analysis and presentation is questionable because of an incomplete analysis of air quality effects, including the Corp's failure to consider air quality effects from breaching on certain local populations; and (13) Corps officials said they did not believe the level of emissions would pose a significant impact and lacked enough time or money to study the matter in more detail.

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