Fish & wildlife Independent science IEAB documents

Scoping for Feasibility of Columbia River Mainstem Passage Cost-Effectiveness Analysis

November 2004  |  document IEAB 2004-2

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Executive Summary

The Independent Economic Analysis Board (IEAB) has been asked to review current information about Columbia River mainstem bypass spill and alternative juvenile passage strategies to determine if the information base can support a formal cost-effectiveness analysis (CEA) of any passage options, and if so, how the information can be characterized to represent the range of opinions about the effectiveness and costs of bypass spill and passage alternatives.

For purposes of this analysis the IEAB defines a cost-effective scenario as one that reduces net costs (power revenue losses plus costs of passage actions) and increases juvenile survival relative to the status quo scenario. Therefore, our scoping is concerned with quantitative information about power revenues, passage costs and juvenile survival.

In early 2004, Bonneville Power Agency (BPA) and the U.S. Army Corps of Engineers (USACE), the ?Action Agencies? proposed to modify bypass spill operations at the Federal Columbia River Power System (FCRPS) dams while providing ?offsets? to compensate for the reduced juvenile survival caused by the reduced bypass spill. The scope of the review includes analysis, comments, and response to comments in relation to the ?Preliminary Proposal for FCRPS Summer Juvenile Bypass Spill Operations? (BPA and USACE, 2004a) released March 30, and the ?Amended Proposal for FCRPS Summer Juvenile Bypass Operations? (BPA and USACE 2004b), released June 8. We also describe the proposed revised BiOp as provided by the Amendment to the 2004/2004-2008 Implementation Plan, (USDC 2004c).[1]For the purposes of this paper, the status quo for spill requirements is defined by NOAA Fisheries? 2000 Biological Opinion for FCRPS Operations.

Our descriptions of the proposals and comments include text related to cost-effectiveness taken verbatim from the documents. This body of information provides a current and detailed information base that reveals the range of opinions about the cost-effectiveness of summer spill as compared to other actions to increase salmon and steelhead runs.

Our review finds that

• Conclusive and complete CEA of the modified spill proposals and offsets is currently not feasible because of a large amount of uncertainty regarding their survival effects, because survival effects of some offsets have not been estimated, and because some offsets were not well-defined. Still, we are able to provide some CEA that reflects the range of uncertainty.

• Our review highlights areas of uncertainty most important to the feasibility and cost-effectiveness of actions intended to improve juvenile survival. These are: passage timing, smolt-to-adult survival rates, effects of spill on pool survival, delayed mortality of transported juveniles, and water quality factors (primarily temperature and dissolved gas).

• More advance planning might increase the acceptability of a spill reduction/offset package. It is difficult to propose offsetting actions for a migration season that will begin within months, because most actions take time to implement. Some of the most promising offsets, Removable Spillway Wiers (RSWs) for example, could not be considered for the 2004 migration season.

• Some stakeholders might have been more supportive if more time had been allowed for comments, and if stakeholder proposals had been more directly included in the modified proposals.

• Some offsets were criticized because stakeholders felt they should be regarded as BiOp actions. There needs to be a clear distinction between actions included in the BiOp baseline, and actions above and beyond the BiOp.

If it can be assumed that the Action Agencies? proposals and analysis are correct, then a number of cost-effectiveness implications follow.

• The Preliminary Proposal suggests that reduced bypass spill and proposed offsets would be cost-effective for Hanford Reach fall run chinook stocks. However, the package is not shown to be cost-effective for other non-listed stocks or for the ESA-listed Snake River fall run stock because quantified survival losses are larger than quantified survival increases from offsets.

• The Amended Proposal includes actions intended to fully compensate for reduced survival of ESA-listed Snake River wild stocks. The key action is increased outflow from Brownlee Reservoir. For this ESA-listed stock, the Amended Proposal judges this action to be adequate for offsetting reduced spill. Survival benefits from augmenting the pikeminnow program are shown, but because of an issue involving BiOp requirements, the pikeminnow program augmentation is not counted as an offset.

• The Amended Proposal suggests that reduced bypass spill and proposed offsets would be cost-effective for the Snake River fall chinook wild and hatchery stocks, for the Hanford Reach natural stock, and for all non-listed stocks (including Hanford Reach) taken as a group. The cost of all proposed offsets ($10 million annually) is forecast to be less than the increased revenue from reduced bypass spill ($33 to $44 million annually).

• The pikeminnow program augmentation is not counted as an offset. However, an analysis is presented in an appendix to the Amended Proposal (BPA and USACE 2004d)showing that, for most non-listed stocks, the amount of survival increase from pikeminnow program augmentation is less than the survival reduction from reduced spill. For these stocks, survival benefits from other offsets (habitat improvements for natural fish and hatchery actions) are not quantified. Therefore, for these non-listed stocks, the analysis provided by the Amended Proposal does not show that proposed offsets can increase survival enough to compensate for reduced spill, even if the pikeminnow augmentation program is counted as an offset.

• The Amendment to the 2004/2004-2008 Implementation Plan for the FCRPS Biological Opinion Remand (the Revised BiOp) issued in June 2004 proposed relatively small changes to the Amended Proposal. At Ice Harbor and John Day, BiOp spill would end on August 25 instead of August 21. NOAA Fisheries (USDC 2004) finds that survival increases for Snake River fall chinook salmon from increased Brownlee releases are adequate to offset survival reductions from reduced bypass spill. Based on this opinion and likely power benefits and costs, the Action Agencies argued that this change is likely to be a cost-effective change for management of the Snake River fall chinook stocks. Again, increased net survival and cost-effectiveness were not demonstrated for the majority of the affected Columbia River stocks

There is substantial controversy about many factors affecting the cost effectiveness of mainstem actions.

• Tribal interests, environmental groups and fish and wildlife agencies raised many issues with the biological analysis used to support the Preliminary Proposal. Taken at face value, the juvenile survival issues raised by the comments imply much uncertainty regarding the cost-effectiveness of the Preliminary Proposal. An alternative analysis provided by CRITFC suggests negative effects on ESA-listed adults about 10 to 15 times as large as the Action Agencies? analysis.  An analysis provided by the Fish Passage Center (FPC) suggests negative effects about 10 to 20 times as large.

• Most controversy is associated with juvenile survival and smolt-to-adult returns. Some important areas of controversy involve passage timing, smolt-to-adult survival rates, effects of spill on pool survival, delayed mortality of transported juveniles, and water quality factors, primarily temperature and dissolved gas.

• There is much less debate about changes in power production and revenue savings from bypass spill reductions, and about the costs of the offsets.

Table ES-1 shows the range of estimated effects on adult fish based on analysis provided by the Action Agencies and selected commenters. Alternative estimates were selected because they represent different opinions, not because the opinions have any more or less scientific merit.[2] Table ES-1 reveals the range of impacts suggested by the Preliminary Proposal and comments, and it shows that, for some stocks, estimated survival benefits of offsets were not large enough to compensate for losses from spill reduction.

Table ES-1. Estimated Change in Adult Returns Under Preliminary Proposal.
Action Agencies? Estimates, and Alternative Estimates

• In the comments provided for the Preliminary Proposal, many alternative offsets were proposed for reduced spill, and some data on effectiveness and costs were provided. For Columbia River stocks, many of these offsets might be reasonable and cost-effective alternatives to bypass spill. Quite possibly, some of these may be cost-effective alternatives to the offset actions proposed by the Action Agencies.

• In the Preliminary Proposal and comments to it, there was no analysis of any offset or combination of offsets that would compensate for reduced spill impacts on ESA-listed Snake River wild stocks (see first row and last two columns of Table ES-1). The Amended Proposal includes increased outflow from Brownlee Reservoir, but it is not clear that this offset would have the intended benefits, and because of water temperature effects, could actually be counterproductive.

The IEAB is unable to make an unambiguous statement about cost-effectiveness of spill reductions because 1) some of the necessary biological information has not been provided, and 2) where information is disputed, we are not qualified to judge and resolve the disputes. To obtain more definitive results, new information about some of the offsets is required, and judgments regarding the disputed information are required. The IEAB's role simply does not include such judgments.

Clearly, there is a need for a process that can include offsets such as RSWs that can only be implemented in the long run. The 2004 process for proposing spill reductions and offsets was simply too short to consider all forms of potential offsets. A long-term process would also be better able to involve stakeholders, conduct the necessary research, resolve key issues, and recommend changes in a fully inclusive and scientific way. The Council should continue to encourage research and processes that might reduce the biological uncertainties, evaluate alternatives to spill, and identify cost-effective outcomes.

[1] On July 28, Judge Redden in the District Court of Oregon ruled in favor of a motion for a preliminary injunction to stop implementation of a modified summer spill proposal. As of September, bypass spill in 2004 conformed to the 2000 BiOp.

[2] The IEAB is not qualified to evaluate biological information and arguments.

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