INTRODUCTION
BACKGROUND
Purpose of the Review
Background on CRFM Program
CRFM Program Costs
Goal and Objectives of CRFM Program
Scope of Review/Procedures and Coordination
Policy Context for the Review
ISAB Reports in Three Phases
SUMMARY OF ISAB TECHNICAL FINDINGS AND PROPOSED COUNCIL RECOMMENDATIONS
OVERVIEW OF COMMON ISSUES IN MAINSTEM FISH PASSAGE
ISAB Overview Report
Focus on Biodiversity and Natural Behavior Patterns and River Processes
Staff's Proposed Council Recommendations
SPECIFIC ISSUES IN MAINSTEM FISH PASSAGE
Background for Juvenile Fish Bypass Improvements
Bonneville Dam Juvenile Fish Bypass Improvements
ISAB Findings
Summary of Comments
Staff's Proposed Council Recommendations
Installation of Extended-Length Screens at John Day Dam
ISAB Findings
Summary of Comments
Staff's Proposed Council Recommendations
Development and Testing of Surface Bypass Systems
Background on Surface Bypass Systems
ISAB Findings
Summary of Comments
Staff's Proposed Council Recommendations
Corps' Dissolved Gas Abatement Program
Background on Dissolved Gas Abatement Program
ISAB Findings
Summary of Comments
Staff's Proposed Council Recommendations
Adult Fish Passage
Background on Adult Fish Passage
ISAB Findings
Summary of Comments
Staff's Proposed Council Recommendations
INDEPENDENT ENGINEERING REVIEW OF CORPS' CRFM PROGRAM
Background
Value Engineering
Technical Review
Project Partnering
Summary of Comments Received on Issues
Staff's Proposed Council Recommendations
INTRODUCTION
Congress asked the Council, with the assistance of the Independent Scientific Advisory Board (ISAB), to review the Corps of Engineers' Columbia River Fish Mitigation Program (CRFM Program, or Program). This paper summarizes the technical findings and recommendations of the Independent Scientific Advisory Board (ISAB) to the Council and National Marine Fisheries Service (NMFS) concerning the Corps of Engineers' CRFM Program.
Based on the ISAB review and other considerations, the Council will be making a decision in late April as to what policy recommendations to make to the Corps and to Congress regarding the CRFM Program. So this paper also contains staff recommendations for what might become the Council's policy recommendations in April for the CRFM Program. We plan to circulate this issue memorandum for a public review and comment period, along with the ISAB's final overview report (ISAB Report 99-4).
BACKGROUND
In the Conference Report on the FY 1998 Energy and Water Development Appropriations Act (H. Rept. 105-271), Congress asked the Council to review the Corps' CRFM Program:
The conference agreement includes $95,000,000 for the Columbia River Juvenile Fish Mitigation program in Washington, Oregon and Idaho instead of $85,000,000 as proposed by the House and $117,000,000 as proposed by the Senate. The Conferees note that the budget request for this program appeared to reflect the pursuit of multiple restoration strategies. Some of these may not be adopted, rendering expensive measures obsolete. The conferees request the Northwest Power Planning Council, with assistance from the Independent Scientific Advisory Board (to the extent that the Board feels it can participate without compromising its primary function) established jointly with the National Marine Fisheries Service, to conduct a review of the major fish mitigation capital construction activities proposed for implementation at the Federal dams in the Columbia River Basin, including those called for in the 1995 Biological Opinion of the National Marine Fisheries Service regarding the Snake River salmon. The review shall be completed by June 30, 1998. Upon completion of the review, the Corps of Engineers shall seek regional recommendations, as provided by the Bonneville Power Administration Fish and Wildlife Budget Memorandum of Agreement dated September 16, 1996, on implementing the recommendations contained in the review. In addition, the findings of the review shall be supplied to the House and Senate Appropriations Committees.
On April 30, 1998, the Council and the ISAB advised Congress that, because of the complexity and magnitude of this review and the need to conduct a thorough review of research to provide recommendations that ensure a scientific basis for future decisions, this review would be conducted in three phases. The final phase of the ISAB's review, which accompanies this report, was completed on February 16, 1999, with a presentation to the Council on February 23, 1999.
Purpose of the Review
Congress asked the Council to conduct this review primarily because of concerns that the CRFM Program appears "to reflect the pursuit of multiple restoration strategies, some of [which] may not be adopted, rendering expensive measures obsolete." Hence the main purpose of the capital construction review is to identify the need for multiple passage strategies and whether some strategies can be modified, deferred or even eliminated, especially for technical or scientific reasons.
Background on CRFM Program
The purpose of the CRFM Program is to mitigate adverse effects of the eight Corps of Engineers' (Corps) hydroelectric dams on the Lower Snake and Columbia rivers on anadromous fish. The mitigation consists of fish passage improvements to the eight federal dams, principally to safely pass juvenile salmon, but also to improve adult passage. The scope of the CRFM Program is largely shaped by measures contained in the March 1995 Biological Opinion issued by the National Marine Fisheries Service (NMFS) on the impacts of the federal hydropower system operations on Snake River chinook and sockeye salmon, as well as newer measures in the NMFS 1998 Supplemental Biological Opinion for steelhead. (Six species of anadromous salmon that spawn in the Snake or in the Columbia above one or more of the dams are currently listed as threatened or endangered under the Endangered Species Act; more are proposed for listing with NMFS' decision on listing expected in March 1999.) The Program also considers and implements capital construction measures for mainstem fish passage contained in the Northwest Power Planning Council's (Council) 1994 Columbia River Basin Fish and Wildlife Program, as well as the tribal 1995 salmon restoration plan, Wy-Kan-Ush-Mi Wa-Kish-Wit -- Spirit of the Salmon.
The Corps and other federal agencies coordinate the prioritization and implementation of the various projects or measures in the CRFM Program with other regional entities through what is known as the System Configuration Team (SCT). The SCT was established to fulfill a requirement of the NMFS 1995 Biological Opinion (reasonable and prudent action #26), and to serve as a technical coordinating committee in NMFS Columbia Basin Anadromous Fish Program Implementation process of February 1996.
Each year the SCT is responsible for establishing project priorities and developing recommendations to the Corps for implementation of physical improvements to juvenile and adult fish passage facilities on the mainstem Snake or Columbia Rivers. The annual project priorities and recommendations are based on actions or measures identified in the relevant Biological Opinions and salmon recovery plans. Absent consensus in the NMFS Regional Forum, the Corps makes the final decision whether or not to implement a CRFM project. Initial scoping and scheduling of a CRFM project is accomplished within the Corps' Fish Facility Design Review Work Groups. Membership on the SCT is open to the Corps of Engineers, Northwest Power Planning Council, NMFS, BPA, Bureau of Reclamation, USFWS, and state and tribal fishery agencies. The SCT is co-chaired by representatives from NMFS and the Council.
A September 16, 1996, Memorandum of Agreement (MOA) among the Departments of Army, Commerce, Energy and Interior concerning the Bonneville Power Administration's (BPA) financial commitment for Columbia River Basin fish and wildlife expenditures created additional incentives for regional coordination. Funds to implement CRFM Program measures are requested by the Corps in the federal budget process and are appropriated annually by Congress. BPA reimburses the U.S. Treasury for the costs attributable to federal hydropower production, an average of 80 percent of the capitalized costs for each project, when construction is completed and the project is operational. Under the budget MOA, the Corps of Engineers committed that when submitting budget requests for capital appropriations that will be reimbursed by Bonneville, the regional office of the Corps will "act in a manner consistent" with "regional priorities and recommendations" for the allocation of capital funds. If the Corps' eventual budget request differs from regional priorities, the Corps is to explain to Congress and to the region "the reason for the difference and the impact of the difference on the ability to carry out other activities."
There are over 50 separate projects or measures in the Corps' CRFM Program either in the implementation (capital construction) or study/investigation phase. While much of the CRFM Program budget is devoted to actual capital modifications at the dams, projects or measures in the study/investigation phase are also included in the Program. Such projects include studies of new fish passage technologies related to alternative system configuration proposals, including surface bypass, dissolved gas abatement, turbine passage survival, adult fish passage, and drawdown or dam breaching proposals for the four lower Snake River and John Day dams. In recognition of the Conference Committee report language accompanying FY 1999 Congressional appropriations, work on phase 1 of the John Day drawdown study is beginning this year based on a project study plan developed regionally in January 1998.
CRFM Program Costs
Since inception of the CRFM Program in 1988, the current total Program cost estimate is about $1.4 billion, which includes an allowance of $500 million for future system configuration changes and fish passage improvement measures. Cumulative Program expenditures through FY 1998 total approximately $465 million, another $81-82 million is scheduled to be spent in FY 1999, and the Administration's budget request for FY 2000 is for $100 million. About 46 percent of the Program effort in FY 1999 will be on Mitigation Analysis studies, which includes continuation of: a) surface bypass prototype construction, modeling and evaluations at Bonneville and John Day dams; b) completion of lower Snake River drawdown feasibility studies; c) gas abatement and spill studies; d) turbine passage survival studies; and e) additional adult fish passage studies. The majority (54 percent) of the Program effort in FY 1999 will be implementation of fish passage improvements, including continuing construction of Bonneville Dam juvenile fish bypass improvements, including relocation of the bypass outfall; construction and prototype testing of new extended-length fish screens at John Day Dam; implementation of various adult fish passage improvements; and engineering design work on other fish passage improvements.
Goal and Objectives of CRFM Program
The current general goal for mainstem fish passage, as stated in the NMFS 1995 Biological Opinion, is for the Corps to implement all reasonable measures for the operation and configuration of the Federal Columbia River Power System that will reduce mortalities of listed fish, for both juveniles and adults. The biological objectives of mainstem fish passage actions are to minimize a) delays at dams and b) the passage of fish through turbines by c) providing high survival alternative passage routes supporting salmon smolt-to-adult survival ratios that foster long-term population growth.
The interim performance objective for CRFM Program juvenile passage improvements is to achieve at least an 80 percent fish passage efficiency (FPE) and a 95 percent survival rate for juvenile fish passing at each dam, while keeping total dissolved gas levels within the limits of state water quality standards under the Clean Water Act. In addition, the performance objective for upstream passage is to ensure a high degree of adult passage success by maintaining adult fish facilities within criteria established in the Corps' Fish Passage Plan, and make facility improvements, where necessary. Specific adult fish passage criteria have not been developed or agreed to within the region.
Note it is the needs of listed Snake River populations, as identified by NMFS in the 1995 Biological Opinion, that drive the current CRFM Program. The states, the Council, the four lower river treaty tribes, and others have plans and programs that in some respects would set different goals and priorities for the modification of the projects. Those perspectives are brought to the attention of the federal agencies, but in the end the agencies have deferred to the direction set by NMFS Biological Opinion.
Scope of Review/Procedures and Coordination
The Council approved a scope of work for the capital construction review based on regional comments received on a draft scoping document (Ruff, 1998). In addition, the Council, through its staff, prepared a technical background paper on the CRFM Program, which was used by both the Council and the ISAB to provide needed background information for their respective reviews (Technical Background Paper-Review of the CRFM Program, 1998). A third document, Council report #97-15, was also used as a reference report during the review process.
The scope of the review included identification of those specific elements (projects/measures) that needed focused review plus the policy and technical questions/issues that needed to be addressed. Questions or issues of a policy nature have been or are to be addressed by the Council, while technical/scientific questions have been reviewed by the ISAB.
CRFM Program projects can be placed into major categories such as surface bypass, juvenile fish bypass improvements, spill bypass and dissolved gas abatement, smolt transportation, reservoir drawdown/dam breaching and adult fish passage. Because of the large number of individual projects and the complexity of many, the review focused on an evaluation of the major fish passage strategies, as well as several controversial projects, in order for it to be completed by February 1999. The review focused primarily on passage improvements proposed for implementation rather than on those already underway or those in the research phase.
Specifically included in the ISAB's technical review were three capital improvement projects that were controversial in 1997 during the SCT's deliberations of the Corps' FY 1998 CRFM Program budget. Those projects include: 1) the Bonneville Dam second powerhouse juvenile fish bypass improvements, particularly the bypass outfall relocation; 2) installation of extended-length screens at John Day Dam; and 3) further development and testing of the surface spill bypass prototype system at Lower Granite Dam on the Snake River.
The Corps' research projects, implemented under its Anadromous Fish Evaluation Program, will be reviewed separately in future years by the Independent Scientific Review Panel (ISRP), and integrated into the Panel's annual review of BPA direct-funded research. Due to the short time frame for this review and heavy ISAB workload in 1998, and since Corps research-related issues will be addressed in the ISRP review process, those projects are not included in this review.
Various technical briefings on particular CRFM projects undergoing review were scheduled during the ISAB's deliberations. These briefings, which were provided by members of the region's fishery agencies, tribes and the Corps, presented relevant technical information on specific projects for the panel's consideration. In addition, following each of the ISAB's reports to the Council on its findings and technical recommendations of various aspects of the Program, the Council provided opportunity for public comment on the ISAB reports and the policy issues arising from these reports. This final report by the Council incorporates the technical/scientific findings and recommendations from the ISAB, as well as the public comments received on the policy issues raised in this review.
The Council utilized the regional SCT to provide technical input throughout the 15-month capital construction review process. Additional coordination with the region's fish and wildlife agencies and Indian tribes was provided with staff assistance from the Columbia Basin Fish and Wildlife Authority (CBFWA). In addition, the Council compiled a list of entities not represented on SCT that were interested in participating in the review of mainstem fish passage capital construction projects. The Council used that list for consultation purposes during the review process.
Policy Context for the Review
Review of the CRFM Program has not focused on purely scientific questions. Instead, the review was conducted within a policy context that relates to an eventual set of system configuration decisions affecting the use or relevance of fish passage facilities at existing mainstem dams. Accordingly, it was necessary to establish some policy sideboards for the review effort. For example, the question of the value of installing extended-length screens at particular mainstem dams is only important if the projects are to remain operating in their existing condition.
The Council is charged to balance the region's need for an "adequate, economical, efficient, and reliable" power supply, with its obligation to "protect, mitigate and enhance" the fish and wildlife of the Columbia River Basin. To aid the ISAB review effort, the Council established a policy context for the review of the CRFM Program related to possible major future system configuration alternatives of mainstem hydroelectric dams presently under consideration in the region. Accordingly, the following four future alternative scenarios were identified by the Council to provide policy sideboards for the technical review:
1. All existing mainstem dams, including dam modifications, remain in place and operational for the foreseeable future. 2. All dams remain in place except that the four lower Snake River projects are breached to provide a natural river condition in the Snake River within the next 5-10 years. 3. All dams remain in place except that a lower Columbia River project, such as John Day Dam, is breached or lowered within the next 10 years. 4. Dams remain in place except that the four lower Snake River projects are breached to provide a natural river condition in the Snake River and John Day Dam is breached or lowered in the Columbia River within the next 5-10 years.
The technical elements of the review were analyzed by the ISAB based on these four potential future scenarios. The final determination as to which system configuration alternative to implement will continue to be a regional and national policy decision to be made within the next year or so.
ISAB Reports in Three Phases
Partly at the request of the Council, the ISAB broke up its review into three phases, to allow for review and recommendations early in the review process on certain high priority questions. The ISAB's first report, ISAB 98-4 (June 9, 1998), addressed questions from the Council about the proposed installation of extended-length turbine intake screens at John Day Dam and the proposed relocation of the juvenile fish bypass conduit at Bonneville Dam. In the second phase, the ISAB submitted two reports to the Council on September 29, 1998, responding to questions from the Council regarding development of surface bypass for juvenile salmonids (ISAB 98-7) and abatement of supersaturated gas caused by spill operations at hydroelectric projects (ISAB 98-8). The third and last phase also involved a pair of reports -- ISAB 99-2 (January 26, 1999), which reviewed adult fish passage measures in the Corps' capital construction program, and ISAB 99-4 (February 16, 1999), which provided an overview of the Corps' CRFM Program and the ISAB's review of that Program.
SUMMARY OF ISAB TECHNICAL FINDINGS AND PROPOSED COUNCIL RECOMMENDATIONS
OVERVIEW OF COMMON ISSUES IN MAINSTEM FISH PASSAGE
ISAB Overview Report
Focus on Biodiversity and Natural Behavior Patterns and River Processes
Because the Council had specific questions about specific issues, the ISAB first produced a series of reports on these specific issues -- the Bonneville outfall, John Day extended-length screens, surface bypass systems, gas abatement, and adult passage. But the Council and the ISAB both realized that the CRFM Program review would not be complete if the ISAB could not offer general principles tying the specific reviews together in a broader context, to help guide the Corps, the Council and others in making decisions beyond the specific issues already addressed. To produce such an "overview" report, the ISAB examined their project-specific reviews to identify the issues common to all of the projects and placed these projects in a "larger ecosystem context." The ISAB then defined what it hopes are "clear and understandable principles and guidelines that can direct not only the specific project, but the approach to all such measures." The ISAB then collected these into what it called a Test of Biological Effectiveness. The ISAB also answered several general and specific questions posed by the Council, summarized its previous reports in the series, and commented on several policy issues before the Council.
All of the ISAB's overview report is worth study, but we will focus on the report's discussion of common issues, principles and guidelines in an ecosystem perspective. The themes discussed in this part of the report echo throughout the rest, especially two interrelated themes:
1) protect biodiversity -- passage solutions must be designed to benefit the range of species, stocks and life-history types in the river, even if this means we need multiple passage solutions at a project, and 2) favor passage solutions that best fit natural behavior patterns and river processes -- the best passage solutions are those that take into account and work with the behavior and ecology of the species and life-history types using the river system, that "mimic the natural situations and processes that emigrating salmonids encountered in their evolutionary history."
The two principles are linked: "Technologies that most closely approximate the natural physical and biological conditions of migration would seem most likely to accommodate diverse species/stocks." Multiple passage methods at each dam are also a rational result of considering these two principles: Thus the ISAB noted that surface spill and surface bypass systems with adequate attraction flows in the dam forebays most closely match the requirements for salmonids that migrate in the upper waters of the river. But, this approach discriminates against species that migrate primarily near the bottom of the river, such as lamprey. No technology tested to date has even tried to effectively pass these deep-water fish. Innovative turbine designs that can pass deep-water fish with much less mortality may be part of the answer, or completely new bypass approaches may be necessary.
The point of the ISAB report is that these two principles should become the driving biological considerations in decisions to modify the dams to improve passage. Yet these two concepts have influenced passage decisions only occasionally and often only by accident or force of circumstances: for example, the continued emphasis on spill as the default passage option because bypass systems cannot meet passage objectives; the relative success in juvenile passage at The Dalles Dam by using an ice and trash sluiceway not intended for fish passage; the introduction of the surface bypass concept after realizing the juvenile passage benefits incidental to the hydrocombine design at the Wells Dam; the slow development over time of adequate attraction flows at the entrance to the adult ladders; and the existence of multiple passage options at a number of dams, which may help to protect biodiversity, but in existence only because of the region's conflicting understanding of the effectiveness of any one option. The region needs a decisive change in how it makes passage decisions so that these considerations are no longer accidental.
Ecosystem Perspective/Protecting Biodiversity. Focusing especially on the issue of biodiversity in its "ecosystem perspective," the ISAB concluded that proposed improvements in the CRFM Program "fall short of an ecosystem approach that would seek to implement measures designed to maximize the proportion of migratory fish species protected." Each modification tends to focus on improving survival of a segment of the life history of salmon without linking the segment to the rest of the life cycle or considering the impacts on other species or life history types. Thus, the current configuration and operation of bypass systems and other capital improvements "contribute to erosion of biodiversity by selectively favoring certain life histories, stocks, and species over others." If means cannot be found to configure and operate bypass systems and other passage improvements to achieve some measure of protection for biodiversity, "we see continued erosion of biodiversity to be inevitable." The ISAB recommended that the Corps develop a process to inquire whether existing, proposed or alternative improvements in passage technologies can meet a biodiversity standard.
Responding to the current interest in the most recent data showing increases in in-river migration survival, the ISAB noted that Columbia River dams with fish passage facilities have an "impressive record of accomplishment compared to dams without passage facilities." But when the standard of comparison is a natural river, "it is not clear that fish passage facilities have had positive effects beyond prolonging the process of extirpation." Gains in juvenile survival through the hydrosystem are not correlating to increases in adult returns to spawning, the critical final measure. And the relatively high values recently measured for mainstem passage survival of some species "may refer only to those stocks that have been able to adapt to the juvenile transportation system, or to passage through mainstem dams and reservoirs, while those that were not able to do so no longer exist." The ISAB found this point critical for this reason -- effective restoration of salmonids to the Columbia River may depend far more on protecting and restoring biodiversity than simply increasing abundance. In Return to the River, the ISAB argued that "habitat degradation and loss of connectivity among habitats has suppressed life history and stock diversity. Major life history types (e.g., subyearling migrants) and stocks have been extirpated or severely reduced in abundance. Natural production of spring chinook salmon is largely confined to relatively small, isolated populations in headwater streams where habitat is apparently still relatively pristine." Thus the challenge we face is to decide "if the best opportunities for restoration can be found in maintaining or increasing abundance of the few remaining stocks (just managing the 'survivors'), or on reestablishing extinct and recovering severely depressed stocks. If the latter, dams may have contributed to the demise of those stocks that could not adapt to the present hydropower system configuration. Consequently, major changes in the hydropower system could be needed for restoration of the full diversity of stocks." Common Issues and Principles. A summary of the ten common issues and corresponding principles described by the ISAB (in a somewhat different order than in the ISAB report, to bring similar principles together) reflect further the twin themes of protecting biodiversity and favoring natural behavior patterns and river processes:
Spill/Natural Behavior and River Processes. "The general principle we see here is that all juvenile passage alternatives should be evaluated against the baseline of spill. The biological baseline is <2% mortality in spill, followed by increasing in-river mortality when gas supersaturation is generated above about 120%." The ISAB began its examination of common issues by noting that "some avenues of passage, such as spill, more closely mimic natural situations and processes that emigrating juvenile salmonids encountered in their evolutionary history than others. Consequently, such means of passage should more closely reflect natural selection over the entire range of stocks and life history types than more unnatural passage routes." The ISAB noted that ranges of survival in spill can vary substantially from the baseline depending on the project and proportions of flow spilled. Also, much still needs to be done to understand and produce gas conditions that are consistent with the conditions under which salmonids evolved, and more needs to be known about the relative efficacy of spill compared to other possible passage methods. But no other passage method consistently meets the biological baseline of spill, for a reason the ISAB believes is telling -- spill remains the most "natural" of passage routes, all things considered. Thus the ISAB recommended that spill should continue to be used until improvements from other bypass technologies achieve the fish passage goals of NMFS or the Council, considered broadly. "Identifying and implementing more natural passage routes would increase normative conditions at each dam and should result in a decrease in juvenile mortalities."
Site Specificity v. General Biological Premises. "The principle is to foster a design process that meets the generic needs of fish first, and then adjust the design to the specific characteristics of the dam secondarily and to put emphasis on commonality of purpose and function first." While recognizing that every dam in the federal hydrosystem is unique, and thus that fish passage solutions require site-specific attention, the ISAB concluded that "site specificity was often unduly overriding inherent commonalties. Despite an exceptionally clear statement of general biological premises for the surface bypass program, for example, we saw applications at each site taking a largely trial-and-error approach." Returning again to one of the key themes, the ISAB lamented that "[a]pplication of the biological principles of fish behavior and physiology has been subsumed under questions of building structures to fit the features of a particular dam."
Importance of Premises and Hypotheses. "The principle we derive from these comparisons is that explicit statement of biological premises is a valuable aid for efficient development of fish passage technologies." Given the ISAB's core themes, it was not surprising to find the scientists recommend "that all projects be made to list their [biological] premises explicitly and summarize the evidence in support of those premises before construction and testing of prototypes proceeds." Premises and assumptions form testable hypotheses that can guide further research and development, reducing both trial-and-error approaches and the tendency to keep making relatively minor adjustments to existing technologies without a good biological basis. In an example that illustrated again the ISAB's biological preference for passage solutions that best fit natural behavior patterns and river processes, the ISAB noted that it would be useful to see the biological premises for extended-length screens further developed "to include hypotheses about the entire sequence of events leading to successful screening. These hypotheses would need to address delay of surface-migrating fish in dam forebays, behavioral and physiological reactions of fish being drawn into deep turbine intakes from surface waters, tendency of fish to follow flow once committed to the turbine intake, surface-seeking behavior of fish in intakes that guides them to gatewells, and so forth." In contrast, the ISAB noted how "refreshing" it was to see in the surface bypass development that the program had specifically laid out the biological premises of the work, and planned the research to address those premises as testable hypotheses.
Biodiversity. "The principle is simple--strive to make dam modifications that will benefit the suite of species and stocks using (or that once used) the river system. Where designs are favoring one segment of the suite, multiple systems may be needed to include the other species and stocks. No guiding concept is repeated more times in more ways by the ISAB. To quote in full here: "Biodiversity of salmon and steelhead stocks may not be protected by the intake screen systems in use or by other planned technologies. Ample evidence is available to demonstrate that the collection efficiency of each bypass system varies by species, life history type and population. This was a recurring concern about each construction project. The FPE goal, if implemented over the long term, could increase survival of some stocks and life history types that pass through the existing system at an optimal time, while the survival of other stocks and life history types that pass through the system at other times could be unaffected or adversely affected. The FPE goal for each technology should reflect the need to achieve high passage efficiency and survival for all stocks and/or species throughout the entire seasonal migration period. Each of the individual stocks must pass through the selective mortality bottleneck imposed by the mainstem dams. This goal may be unattainable, but dam modifications can still be constructed to maximize the likelihood of all species and stocks being protected."
Inconsistent Measures of Performance. "The principle is the need for the common "currency" of stock specific performance for measuring performance of system improvements. Stock specific performance is the ideal standard, however technically challenging it may be to attain." The ISAB noted a "critical clash of performance measures between the upper-river salmon restoration programs and Corps mainstem passage programs," a clash with significant implications for protecting biodiversity. The upper river programs, especially those driven by the ESA, employ performance criteria focused on sizes of individual stocks or spawning populations. Yet the mainstem passage decisions, such as levels of spill or choice of construction projects, are instead "based on an average value for each stock that is weighted toward the most abundant species and stocks." These averages "may be insufficient for the higher measure, that of ensuring that changes in downstream survival would have a beneficial effect for the particular stocks. This is particularly important when there are endangered or threatened species involved, because there is large variability from year to year in the relative abundance of the species and stocks." None of the individual passage technologies meet the performance criteria set by NMFS or the Council; no one even considers whether any meet the more strict standard the ISAB calls for in the overview report, which requires separately determining whether we are meeting passage goals for each of an assemblage of species and life history types in the river. To meet this latter standard, "it will be necessary to think in terms of suites of measures, [such as] a combination of spill with intake screens for passage of juveniles," and to focus the performance evaluation "on the benefits each year to the threatened and endangered stocks, not on the average mix of stocks encountered over a series of years."
Long-Term vs. Short-Term Goals. "Two general principles emerge. One is that the long-term goal of adult returns must be kept in mind even as short-term remedies are proposed and built. The second is that markedly new approaches must be developed and tested instead of minor adjustments to present technologies." In the ISAB's view, capital expenditures designed to improve survival of juvenile salmon should be evaluated as to whether they will lead to increases in adults to the spawning grounds. "The current inability to relate improvements in survival of juveniles from a capital project to improvements in adult returns is disturbing. It may be due to numerous factors, including inadequacies in the data or in the approaches used for measurement, or in the masking of effects by variables that have not been measured." Given the complexity of the ecosystem and the salmon life cycle, current population conditions, and the nature of the existing passage technologies, minor improvements to those technologies have little relevance to long-term adult return goals. That is not to say, according to the ISAB, that we should ignore the short-term perspective. "If a clear biological standard is applied to prospective actions, many short-term actions could have markedly positive effects on salmon survival."
Scheduling Salmon Recovery Measures. "The principle is that clear criteria based on biological needs for successful fish passage are required to do the sort of prioritization among projects over time required by the Congressional mandate."
Passage Options Are Interrelated. "The general principle is that decisions about fish passage measures at a project should be made with the suite of all available alternatives clearly identified, and the interactions among alternatives explored. Options used in tandem may be better than any one alternative used alone. Experience shows that it is not alone sufficient to make modifications of existing technologies." The ISAB noted the "efficacy of any bypass technology at a project, such as bypass outfall relocation or improving fish guidance efficiency (FGE) of screens at Bonneville, is a function of the potential success of alternative measures for improving survival of juvenile salmon, such as improved spill effectiveness, surface bypass development, or gas (supersaturation) abatement." Thus the availability of surface bypass and the feasibility of gas abatement will influence the policy decisions on outfall location, screens, and what proportion of the juvenile salmon and steelhead would be passed via spill. "Decisions for expenditures on FGE improvements or outfall relocation ought to be balanced against the probability that other means may be developed for elevating the fish passage efficiency and the project survival at the particular dam."
Diversion v. Destination. "The principle is that diversion technologies and destinations should not be linked in the pursuit of alternative configurations." The ISAB criticized the "tendency to link the methods of diverting smolts at dams with particular destinations after the dam is bypassed." For example, a surface collection/bypass system could have many end destinations -- diverting fish to the spillway (as done in the Lower Granite Dam prototype), to bypass piping leading to the tailwater, or to the smolt transportation system. A set of extended-length screens could divert fish through the bypass piping to in-river passage or to transportation. The emphasis should be on designing the most effective diversion systems without being limited or constrained by traditional bypass destinations.
More Emphasis Needed on Adult Passage. "The principle is that the few returning adults represent the survivorship of many thousands of initial smolts and they should be given higher priority than they have in the past." As spelled out in more detail in the ISAB's adult passage report, the ISAB concluded that insufficient attention has been given "to identifying and correcting adult passage problems." The scientists "found problems ranging from major discrepancies in counts of upstream migrants at dams to inadequate consideration of major sources of probable mortality, such as fallback requiring multiple passage at a single dam. The uncertainties simply in counting adults under current conditions seem to loom high in priority for resolution, since so much depends upon their accuracy."
Test of Biological Effectiveness. Drawing from these principles, and emphasizing the two core themes noted above, the ISAB crafted what it called its "Test of Biological Effectiveness":
"Our test of biological effectiveness for a proposed action considers whether the action is (1) consistent with the behavior and ecology of the species, (2) supportive of the physical and biological conditions required for successful completion of normal life history requirements for the species, (3) based upon a valid scientific rationale to indicate that the action is capable of assisting in meeting requirements to accomplish the specific objective, and (4) consistent with an ecosystem approach in protecting other species that could be the subject of listing in the future. Examples of specific objectives relevant to the Corps' capital construction program are providing the means for juvenile or adult fish to pass a dam alive, and maintaining or enhancing the health of juveniles and adults passing the dams. A key feature of the test of biological effectiveness is the concept of enhancing the conditions essential to the life history requirements of the species."
In a later section of the report, the ISAB recommended that the Corps and other participants revamp their prioritization and decisionmaking criteria to emphasize these biological considerations.
Staff's Proposed Council Recommendations:
The Council concurs with the ISAB's approach and recommendations. The Council recommends that the Corps and other participants who make decisions on passage modifications revise their decisionmaking processes and criteria to the extent necessary to be consistent with the principles, guidelines and ecosystem perspective set out by the ISAB. This need not mean adopting each and every principle and explanation in precisely the language of the ISAB. It does mean decisionmaking criteria and budget decision explanations that are responsive to all of the ISAB's principles and concerns, but especially to the two core themes of protecting biodiversity and designing passage solutions that favor natural behavior patterns and river processes. Most important, passage standards, targets, designs and evaluations all should focus on protecting the wide array of species and life history types in the river, not just the weighted average or most abundant species, and must ultimately be related to increases in adults back to the spawning grounds, not just the survival of juveniles (or adults) through the system.
On both accounts -- protecting biodiversity and favoring natural behavior patterns and river processes -- spill together with gas abatement measures remains the best passage method, and should be the baseline against which to measure other passage methods. Much can and should be done, however, in the near- and long-term to improve river conditions for fish during spill, through additional gas abatement improvements and other innovative modifications to spillways to allow for more normative surface spill conditions. On the same grounds, surface bypass systems remain the most promising concept for further development, but an unproven concept whose promise could be lost by over-engineering that loses focus on the natural passage factors that make the concept attractive.
On the other hand, modifying more screen bypass systems to extended-length screen bypass systems appears to be the proposed action least likely to be consistent with these principles. That is not to say that screen bypass themselves should be abandoned, if they provide an effective passage route for some species and life history types, especially if used as part of a multiple passage system. Actually removing a project is the logical biological extension of these two principles; the challenge is whether it is possible to find meaningful passage improvement short of project removal.
The Council requests that the Corps of Engineers consult with the other participants in the prioritization process and then, within six months from the date of the Council's final report, report to the Council and the region on how the CRFM Program prioritization criteria and other decisionmaking standards are being revised to be consistent with the principles and guidelines from the ISAB overview report and the Council's recommendations based on those guidelines. To further the implementation of these principles, the Council -- · expects that the Independent Scientific Review Panel will apply the principles and guidelines in the ISAB's overview and other reports during the Panel's review of the reimbursable portion of the Bonneville fish and wildlife budget, which includes the Corps' CRFM Program; · will itself apply these standards in its review of the ISRP report and resulting recommendations to Congress on the reimbursable budget; and · will recommend to Congress, in its final report in this review and in its reimbursable budget recommendations, that budget requests from the Corps of Engineers be evaluated for consistency with these principles.
Congress asked for this review primarily out of concern about the region's "pursuit of multiple restoration strategies" and the costs of these strategies. The same concern has been heard repeatedly in the region -- that we need to decide on which passage strategy is more effective than all the others and employ that strategy exclusively, saving money and increasing survival. Perhaps the most important point to come out of the ISAB's review of the Corps' program has been to dispel the notion of the one best passage method. Given the very different species and life history types of fish in the river, there is no reason to believe that there will be one way through a dam that is the best way for each type. We may have stumbled into multiple passage strategies through the contingency of keeping alive uncertain options, but the result may be the key in the mainstem to protecting the biodiversity essential to salmon recovery in the Columbia. Under this approach, the goal should be to protect a diversity of species and stocks through use of different passage measures at each dam.
SPECIFIC ISSUES IN MAINSTEM FISH PASSAGE
Background for Juvenile Fish Bypass Improvements
Both the Council's Fish and Wildlife Program and the NMFS' Biological Opinion include a large number of capital construction measures to improve juvenile fish passage at the mainstem Snake and Columbia river dams. These include installation of standard or extended-length screens and various improvements in fish bypass and collection facilities. The tribal salmon recovery plan calls for an emphasis on the modification of existing spill passage systems incorporating gas abatement measures and spill efficiency technology to safely pass all stocks of juvenile salmon and lamprey past hydroelectric dams. The tribes note that mechanical screen bypass systems are only partially effective and may select against certain juvenile salmon stocks and life histories, such as fall chinook and sockeye, and also can be damaging to lamprey, an important species to the tribes. From a tribal perspective, further development of screened bypass systems and transportation will only divert limited salmon funds from other measures more likely to achieve restoration. Accordingly, the tribal plan does not allocate additional capital construction funds to this category.
Bonneville Dam Juvenile Fish Bypass Improvements
ISAB Findings:
The ISAB submitted its first technical review report (ISAB 98-4) to the Council on June 9, 1998. This first report reviewed the scientific basis for juvenile fish passage improvements at Bonneville Dam on the Columbia River, and in particular, the proposed bypass outfall relocation. In their review of existing information, the ISAB concluded that the present juvenile bypass outfall locations at the first and second powerhouses "at Bonneville Dam lead to artificially elevated levels of mortality for downstream migrants." Based on this finding, the ISAB "recommended that the proposed bypass relocation proceed. To the extent that bypass relocation can reduce mortalities for those juvenile salmon and steelhead that may enter the powerhouses, outfall relocation would be supportive of recovery of endangered salmon stocks, and it should reduce artificial selection against later and smaller emigrants that are heavily preyed upon." In conclusion, "the high mortality inflicted upon juvenile salmon by predators at the present bypass outfall locations justifies relocation of the outfalls to locations and habitats where predation rates are expected to be significantly reduced." The ISAB recommended that "relocation of the combined bypass outfall to deeper, swifter water more typical of the riverine migration pathway would contribute to restoration of normative conditions, at least in the short-term." The ISAB noted that, in addition to relocation of the bypass outfall, other planned alterations are scheduled at Bonneville Dam to improve juvenile salmon passage. Such improvements include increasing the efficiency of intake screens at both powerhouses, replacing the existing bypass conduits within each powerhouse, joining the two bypass conduits to a common outfall, investigating surface bypass, and implementing gas abatement measures. The ISAB stated the "recommendation for bypass outfall relocation does not constitute a blanket endorsement of additional changes to the rest of the bypass system at Bonneville Dam." Instead, the scientists encouraged "integrated, long-term planning and study of other planned alterations" at the project.
Summary of Comments:
The Council received numerous public comments concerning fish passage issues raised in the ISAB's review of Bonneville Dam juvenile fish passage improvements. While the BPA concurred with ISAB's recommendation about relocation of the Bonneville Dam second powerhouse bypass outfall relocation, it had concerns about whether the new outfall would be able to accommodate the large flow volumes associated with the surface collection technology under development at the project. NMFS and Corps comments also supported relocation of the Bonneville Dam bypass outfall. On the other hand, the Columbia River Inter-Tribal Fish Commission (CRITFC) disagreed with the ISAB's conclusion that construction of the relocated Bonneville Dam bypass outfall was justified. CRITFC based its difference of opinion on relocating the outfall on "different assumptions regarding operations at the second powerhouse and the fact that [our] opinion incorporates economic considerations that were outside the charge given the ISAB."
Staff's Proposed Council Recommendations:
The Council concurs with the ISAB recommendation that the proposed Bonneville Dam bypass outfall relocation proceed, and has actively supported completion of this project in Congressional budget testimony. The bypass outfall relocation project will be completed and operational in March 1999, in time for the spring juvenile salmon migration period. The Council further encourages the Corps to conduct post-construction biological evaluations of the new outfall to determine effectiveness of the new system.
The Council also concurs with the ISAB that support for completion of the outfall relocation should not be taken as a blanket endorsement of the other proposed changes to the Bonneville bypass system. Instead, the Council recommends re-evaluating the fish passage strategies at Bonneville Dam based on the principles discussed above.
Installation of Extended-Length Screens at John Day Dam
ISAB Findings:
The scientists concluded that "implementation of … extended-length screens at John Day Dam does not appear to be justified" based on a number of major uncertainties and questions associated with the ability of turbine intake screens at the project to divert juvenile emigrants into the bypass system. They noted "a major uncertainty regarding the effectiveness of turbine-intake screens (both conventional and extended-length)," as well as emphasizing the uncertainty surrounding the ability to accurately estimate the fish passage efficiency (FPE) and survival of various species and life history types in passage through the screening and bypass system at John Day. Other uncertainties identified by the ISAB in its report included:
- "Increased gatewell turbulence is a consequence of installing extended-length screens." Prolonged exposure of juvenile fish to such increased turbulence "may lead to higher levels of descaling than current designs of standard screens."
- "Effects on fish of increased debris loads in the bypass systems. An unintended consequence of extended screens is their ability to guide more debris into gatewells where it then travels into the [fish] bypass system," and "debris in dams can pose a serious mortality problem for juvenile emigrant salmonids."
- There are uncertainties in the development of appropriate engineering criteria for these new screens.
- There are numerous uncertainties associated with spill passage as an alternative to screening and bypass system at John Day Dam, which precludes "a comparative evaluation of extended-length screens."
- "There is a substantial likelihood that the screening and bypass system selectively favors some life history types/populations/species over others." They identified a number of "factors that would cause differences in project survival of individual populations emigrating at different times of the year."
- "The use of nominal survival figures creates substantial mortality. The lack of empirical data pertaining to survival of juveniles at John Day to support installation of ESBS, the uncertainties of bypass survival studies, and the potential variability of bypass mortality all lead [the ISAB] to seriously question the magnitudes of projected benefits of John Day [extended screens]."
Moreover, the ISAB noted that "improvements in FGE of turbine intake screening are not consistent with longer-term increasingly normative system configuration strategies." In addition, "the search for effective means of improving survival of the full diversity of salmon and steelhead populations needs to be expanded."
In conclusion, the ISAB noted that "extended-length screens are an incremental technology that provides improvement in average, seasonal FGE over standard screens" but "there is uncertainty over whether increased FGE, if achieved, will translate into increased measurable project survival and increased adult returns."
The ISAB concluded that "implementation of . . . extended-length screens at John Day Dam does not appear to be justified. Instead, the ISAB recommends pursuing existing surface spill alternatives and funding research toward possible deployment of a surface-flow bypass system." At those dams that already have standard or extended screens installed, the ISAB urges regional parties to "integrate their continued use with future installations of new facilities designed to mimic natural processes. Mitigation measures need to improve survival of the full range of diversity in salmon and steelhead populations, while taking into account impacts to other species."
Summary of Comments:
BPA concurred with the ISAB's recommendation "to focus on surface bypass alternatives rather than continued investments in mechanical bypass improvements at John Day. There are both biological and structural uncertainties associated with the new screens at John Day that must be addressed before proceeding with additional significant investments in this technology."
The State of Oregon noted that "deferring installation of the [extended-length] screens in 1999 provides an opportunity to design and conduct valuable scientific studies to resolve these questions [of biological benefits and effects]." Oregon recommended "the region should investigate how extended-length screens benefit or harm certain life stages of salmon and steelhead and [other] species such as Pacific lamprey." Oregon suggested that additional prototype testing of the longer screens be conducted in 1999 at those dams that already have such screens installed.
The CRITFC agreed "with the ISAB's conclusion that extended-length screens at John Day [Dam] should not go forward." In fact, CRITFC concurred that the longer screens "select against certain life stages of certain species" and that "information is lacking [on] the impacts of extended-length screens on lamprey, a species of great importance to the tribes."
NMFS, however, took issue with the ISAB's conclusion not to install extended-length screens. Its comments stated "the preponderance of evidence supports our conclusion that tangible survival benefits are achievable with the installation of extended-length screens at John Day." While NMFS agreed there "remained uncertainties [about] the extent of benefits or impacts to all migrant species," it supported "continued development of extended-length screens at John Day," as well as concurrent studies of surface collection technologies. NMFS also pointed out that "this new [surface bypass] technology will require considerable additional investment and time to be fully developed." NMFS concluded it could not "overlook the potential to realize survival benefits to listed juvenile salmon and steelhead at John Day in the near-term through application of existing [screen] technology."
In its comments, the Corps stated, on the basis of the ISAB's findings, it would "not advocate proceeding with [extended-length screen] implementation at this time but point out that improved [fish] guidance (FGE) at the powerhouse is one tool of several…to improve juvenile fish survival at John Day." Accordingly, the Corps stated it had "deferred action on contracting for permanent [extended-length screen] procurement in 1999." Instead, the Corps noted it would "seek regional recommendations on implementing recommendations [contained] in the Council's review [report]." The Corps also pointed out "the ISAB may have incorrectly assumed that installation of [extended-length screens] is intended as the sole effort" at John Day Dam to improve fish passage, and that "higher [fish guidance] provided by the [extended screens] can provide significant survival gains for salmonids relative to other options."
Staff's Proposed Council Recommendations:
The Council notes from the comments above that differences of opinion still exist in the region on the issue of whether or not to install extended-length screens at John Day Dam. The Council concurs with the ISAB's concerns about extended-length screens in general and the John Day screens in particular. No further installation of extended-length screens should occur without answers to these concerns based on further study and prototype testing. Rather than simply cease inquiry into extended-length screens, however, the Council instead continues to support the proposal agreed to by the SCT in 1998, after the ISAB's report, that the Corps construct, install and prototype test a modified extended-length screen design at John Day in FY 1999, at a cost of $2.6 million.
The modified extended-length screen design is expected to address a number of engineering design and structural concerns identified with the previous design. The new prototype screen design will be fully tested during the 1999 spring and summer salmon migration periods to determine its biological effectiveness, including its effects on other species such as Pacific lamprey. Concurrent with these prototype screen tests, the Corps should initiate and expedite evaluations of surface flow and surface spill bypass alternatives at the project. Installation of extended-length screens at the John Day Dam powerhouse should be deferred until sufficient testing of prototype surface bypass systems can be conducted at the project to allow for an informed comparison of the effectiveness of alternative juvenile fish passage alternatives against a baseline of spill passage. This recommendation is consistent with the $95 million FY 1999 CRFM Program budget agreement developed and agreed to by SCT members last fall.
Development and Testing of Surface Bypass Systems
Background on Surface Bypass Systems:
Both NMFS' and the Council's salmon recovery plans place a high priority on research and development to determine the effectiveness of surface-oriented fish bypass systems at mainstem hydroelectric projects. The tribal restoration plan calls for implementation of structural surface bypass measures as a top priority, with emphasis given to installation at the lower Columbia River dams.
NMFS' Biological Opinion calls on the Corps to investigate the application of surface bypass technology at certain lower Snake and Columbia river hydropower dams. Testing of the surface bypass concept began at Ice Harbor and The Dalles dams in 1995. A prototype surface bypass system was designed, installed and tested at Lower Granite Dam beginning in 1996. Testing is to include evaluations of the surface collection and bypass concept at both powerhouses and spillways to determine the effectiveness and safety of passing juvenile salmon. The objective of this work is to develop surface bypass concepts that will significantly improve fish guidance through non-turbine routes; reduce fish stress, injury and migration delay; and reduce high spill volumes which can cause elevated dissolved gas levels and lost power generation. If preliminary testing indicates surface bypass is effective at a conventional powerhouse like Lower Granite Dam, the NMFS Biological Opinion calls on the Corps to begin prototype testing at John Day and/or The Dalles dams. Prototype testing at The Dalles Dam has been deferred due to Congressional budget constraints placed on CRFM Program.
The Council's program calls on the Corps to explore promising new approaches to fish bypass technologies, including development and prototype testing of surface bypass systems, surface-oriented spill systems, and behavioral guidance devices, such as the use of sound, strobe lights and/or physical barriers to help guide juvenile salmon. Prototype testing of surface flow juvenile bypass systems is to be conducted at Lower Granite, The Dalles, John Day, Bonneville and Ice Harbor dams (and under the Council's program was supposed to be completed by 1998). If the results of this research indicate high efficiency at costs less than conventional screening or other bypass system modifications and show no reason to preclude use of this new technology, installation of such surface bypass systems is to be proposed to the Council for incorporation into its fish and wildlife program's bypass strategies.
The tribal restoration plan states that current structural screening and bypass systems at mainstem dams are inadequate for juvenile salmon passage. The tribes recommend further development and implementation of surface-oriented fish bypass systems over conventional screened bypass systems to reduce direct and indirect salmon mortality as well as reducing passage delays and predation on outmigrants. In the near term, the tribes call for expedited prototype development of surface flow bypass systems to address juvenile passage problems at Bonneville, John Day, The Dalles and Ice Harbor dams. However, the tribal plan prioritizes surface bypass development at the two dams where screened bypass systems likely cannot achieve the regional passage and survival goals for both listed and unlisted anadromous fish - both powerhouses at Bonneville Dam and at John Day Dam.
The Shoshone-Bannock Tribes are opposed to the further development of surface or conventional screening and bypass systems at any of the four lower Snake River dams. Instead, their approach is to focus future efforts toward early implementation of natural river drawdowns in the lower Snake River and improvements in adult fish passage.
ISAB Findings:
In its review of the Corps' CRFM Program, the ISAB states that over 20 years of work to develop and "improve turbine intake screen technology has not yet developed a turbine intake screen that can achieve the 80% fish passage efficiency (FPE) standard for all species and stocks." Accordingly, the ISAB concludes "it is time to find an adjunct to the screen technology for [juvenile] bypass," and that "surface collection continues to show promise as a bypass measure for juvenile salmonids." In their report (ISAB 98-7), the scientists point out the surface collector at Wells Dam on the mid-Columbia River is the "only bypass system in the basin that achieves the 80% FPE goal without the addition of spill." At federal mainstem hydro projects the Corps must provide some amount of spill to make up the difference between the 80% FPE standard and the FPE actually achieved by turbine intake screens. The ISAB also concludes the application of "surface bypass technology may be able to reduce the amount of spill needed to achieve the 80% FPE standard."
On the subject of technology transfer, the scientists do not believe surface bypass technology is directly transferable from Wells Dam to other mainstem projects because of their different spillway configurations. They also state that "substantial uncertainties remain regarding the level of changes in survival of juvenile salmon that will be provided by SBC [surface bypass collectors]," as well as how these potential changes in survival will affect the various listed species or other life history types of non-listed species. Based on its review, the ISAB concludes the "development and application of surface bypass technologies is necessarily a slow process because of logistical constraints on the testing of prototypes," and researchers "have only a limited number of alternative configurations that they can test during a given emigration season."
Based on these conclusions, the ISAB's recommendations for surface bypass are:
- The Corps should continue development and testing of surface bypass prototypes in consideration of the following recommendations.
- Careful consideration needs to be given to the locations within the hydroelectric system where surface bypass would do the most good.
- Priority needs to be given to understanding the effect of surface bypass on federally listed species. However, the effects of surface bypass on all species and life history types of native fishes needs to be better understood.
- Development must take into account the need to protect the widest possible biological diversity.
- An aggressive, nontraditional approach to prototype development, which involves fast-track design, construction and testing, should be pursued.
- A time period of approximately ten years should be provided for the developmental phase of surface flow bypass systems to ensure proper and full evaluation.
- Testing should focus on developing data to evaluate the basic set of premises or hypotheses on which surface flow bypass is based.
- A set of alternate hypotheses should be articulated for future testing in the event that any of the basic hypotheses are rejected.
- Development of surface bypass and development of gas abatement measures are closely related and they therefore need to be consistent with each other.
Summary of Comments:
Idaho Department of Fish and Game IDFG) provided the only written comments. While IDFG shared the ISAB opinion that "preliminary tests of prototype surface collectors show some promise, we remain unconvinced that [surface bypass] concepts can improve incremental survival benefits high enough to turn Snake River fish stocks towards recovery"…and "so far, the Lower Granite [prototype surface bypass] tests have not provided [a high enough] level of guidance." IDFG suggested that "fast-track [surface bypass] research and implementation should be directed to those dams that would remain in place whether the Lower Snake projects are breached or not. The [surface bypass] investigations…at the lower Columbia…dams are the best places to focus…prototype design and experimental operation."
Staff's Proposed Council Recommendations:
The Council concurs with the ISAB recommendations and supports continued development and testing of surface bypass prototypes focusing at mainstem lower Columbia River federal hydroelectric projects. This support is premised in part on the ISAB's general conclusion that the concept of surface bypass systems represents a more "normative" passage condition for migrating juvenile salmon than other bypass strategies -- that is, a passage strategy that takes better advantage of and more closely approximates the way many juveniles naturally migrate downstream, i.e., predominantly in the upper portion of the water column -- and that this fact should bring significant increases in survival through the life-cycle compared to other passage methods. The better fit of a passage method to natural migration patterns has been one of the enduring advantages of spill passage over bypass technologies, and thus the promise of the surface bypass concept has been the possibility that it can approach spill passage in this regard while avoiding some of the problems associated with spill.
On this basis, the Council's general statement of support comes with this caveat: It remains to be determined whether reality will prove the concept -- will particular surface bypass systems really prove to be a more normative approach to passage than, for example, traditional screens and bypass or, for that matter, transportation, and will significant increases in survival be the result? Part of this basic question is the degree to which the surface collection concept is simply attached or added on to what are otherwise highly engineered screened bypass/collection systems may rob the concept of its possibilities.
The Council's recommendation for continued research and development of surface bypass technology only at lower Columbia River dams applies at least until the region makes a long-term system configuration decision for the four lower Snake River projects. One caveat to this particular recommendation: Because the existing prototype surface bypass collector at Lower Granite Dam will remain functional for only another year or two, additional prototype testing may be conducted in FY 1999 and 2000 on this system pending continued regional support, technical soundness of the study plans, availability of adequate funds and research applicability to other federal projects. Otherwise, the Council recommends the Corps' highest priority should be for further development and testing of surface bypass prototypes at Bonneville, John Day and The Dalles dams.
In addition, the Corps should pursue an aggressive approach to surface bypass prototype development, i.e., one which involves fast-track design, construction and testing. Given it has taken the Corps over 20 years to develop turbine intake screen technology, the Council recognizes the developmental phase of surface flow bypass systems could take up to 10 years or more to ensure proper and full evaluation of the new technology to compare against other bypass alternatives.
Repeating a primary recommendation from the overview, above, as the Corps and others evaluate surface bypass systems, as well as the other passage strategies (alone or in combination with others), the Council concurs with the ISAB that perhaps the most important concern is the extent to which these strategies provide passage improvements that support the widest possible biological diversity. Single or combination passage strategies that better protect some species (even listed ones) or life history types but fail to provide for the survival of others should not be favored.
Corps' Dissolved Gas Abatement Program
Background on Dissolved Gas Abatement Program:
All three salmon restoration plans call for development of a systemwide gas abatement program, including evaluation and modification, if necessary, of various technologies at mainstem dams to reduce total dissolved gas levels during both voluntary and forced spill operations and to increase spill efficiency. Gas abatement measures that have recently been completed include installation of spillway deflectors at John Day and Ice Harbor dams. Measures under evaluation include end spillbays without fliplips at other dams; design and prototype testing of spillway and stilling basin modifications; and design and prototype testing of structural means, as well as fish behavioral methods, to increase passage efficiency at spillways, including the use of slotted spillgates. Through FY 1998, $15.75 million will have been spent on the gas abatement program. In FY 1999, the Corps plans to spend another $5 million.
While the NMFS and Council approach is directed toward feasibility and prototype evaluations, the tribal approach is directed more toward implementation of structural modifications at the dams. For example, the tribal plan calls for specific improvements at Bonneville and John Day dams where elevated dissolved gas levels limit fish passage through spill and where involuntary spill routinely violates Clean Water Act standards. The tribal plan calls for expedited evaluation and implementation of structural gas abatement measures at these dams to allow spill to occur without substantially raising dissolved gas levels over established standards. The tribes maintain that by prioritizing deep drawdowns at the four lower Snake River and John Day dams, total dissolved gas levels and water temperatures will be significantly reduced. The tribal plan would allocate significant funds for tasks to immediately improve these two key water quality parameters.
ISAB Findings:
The scientists' seven technical findings and recommendations from ISAB Report 98-8 are listed and explained below.
1. The Corps should continue its Gas Abatement Program to reduce dissolved gas supersaturation levels in the mainstem Columbia and Snake rivers to as low as practicable as expeditiously as possible, with a modified set of objectives for the short and long terms.
The ISAB recommends continuation of the Corps' Gas Abatement Program, at a high priority, for three main reasons. First, reduction in total dissolved gas (TDG) supersaturation is needed in high flow years such as 1996 and 1997 that produce involuntary spill, regardless of whether or not spill is used as a management approach to improve salmon passage in other years. Second, some engineering devices have demonstrated effectiveness or high promise for reducing gas saturation to levels that appear biologically acceptable for migrating salmonids in their ecosystem context. Third, an "as low as practicable" approach is consistent with the philosophy of taking actions that will progressively return the river system toward the "normative" condition, even if not all the way to the desired goal (as recommended by the Independent Scientific Group in its 1996 report, Return to the River). Thus, from a biological perspective, the ISAB recommends proceeding with gas abatement to the lowest level practicable at reasonable cost.
2. The objective of reducing the total dissolved gas saturation of the Columbia/Snake mainstem to the Clean Water Act standard of 110% during times when water is spilled at dams involuntarily is unattainable even with major (and apparently impractical or prohibitively expensive) reconfiguration of the hydropower system short of dam breaching or major drawdowns. Attainment of the standard should be considered a policy issue and separated from technical considerations. Technical work should focus on what is technically attainable and biologically acceptable, balancing all relevant risks.
The ISAB noted a major conclusion of the Corps' engineering studies is that the Clean Water Act criterion (and state water quality standard) of 110% gas saturation at the water surface in the spillway tailwater is likely unattainable at any cost in dollars or at acceptable levels of physical damages to migrating salmon when large volumes of spill occur, either involuntarily or for fish passage. This conclusion presumes the dams remain in place, without breaching or major drawdown. For example, field studies of gas entrainment at existing spillways have shown that reducing the depth of plunge basins at dams would be effective in reducing gas supersaturation, but at a high monetary cost with potential loss of juvenile salmon through physical injury. The ISAB cautioned that the devices most effective in preventing spill plunging into deep pools seemed to be the most physically damaging to fish. Thus gas abatement at a dam becomes a balance between induction of gas supersaturation (with effects in the river and reservoir downstream) and the physically damaging side effects of spill abatement at the site.
3. A few critical studies would be useful to refine estimates of the biologically acceptable percentage of atmospheric gas saturation in the context of the salmonid migration corridor, now believed to be about 120%, as a goal for near-term (<10 years) abatement efforts. These studies are considered valuable additions to understanding acceptable levels for migrating salmonids and the mainstem ecosystem, but are not necessary for the Corps' Gas Abatement Program to proceed. These studies are (1) depth distribution of juvenile and adult salmonid migrations and resident aquatic life in relation to gas compensation depth, (2) gas bubble trauma and its critical physiological, behavioral, and reproductive effects in migrating adult salmonids, and (3) effects of supersaturation near 120% (believed safe for migrating salmonids) on other components of the mainstem ecosystem.
The ISAB concludes additional biological studies are not immediately necessary for continuing the gas abatement program. Studies of depth distribution of biota, of adult responses to dissolved gas supersaturation, and of ecosystem responses would be of especially high priority if attainment of a specific safe level of gas supersaturation in the river (above 110% standard) is to be justified on biological grounds. However, the ISAB concludes that full justification of a specific "safe" gas saturation value other than 110% on the basis of biological research is not attainable in a reasonable length of time to conserve dwindling resources nor at reasonable cost. The ISAB concludes that much interesting, scientifically valid, but topically diffuse biological research will not, in the near term, establish the optimal mix of spill and other passage routes for best salmon survival. The alternative of proceeding with gas abatement to the lowest level feasible at reasonable cost is preferable on biological grounds.
4. Physical injury induced by alternative gas abatement devices should be evaluated (and relative risk compared to gas supersaturation in the river-reservoir system and other fish passage approaches) before novel devices are installed.
While the ISAB states that additional biological studies are not necessary for continuation of the gas abatement program, it does recommend that potential physical damages to fish induced by alternative gas abatement structures should be evaluated. Such evaluations may require more research. The scientists state there is "evidence that even relatively proven technologies such as spill deflectors induce a definable increment of mortality that may be comparable to that from other passage routes." They also note "the relative risks to fish from spill with gas abatement devices should be compared to those of unabated gas supersaturation in the river," as well as to fish passage approaches other than spill, such as surface bypass or surface spill.
5. The Corps should continue its efforts to monitor and model the production and equilibration of dissolved gas in the hydrosystem (including gas contributions from Canada) and model the generation of biological effects, and relate its findings to the gas bubble trauma monitoring programs conducted by others.
The scientists recognize efforts by the Corps to synthesize the physical monitoring information in the form of gas generation and equilibration models of the hydrosystem are valuable for developing an assessment tool to analyze alternative abatement technologies. On February 5, 1999, the Corps released its "60 percent report" on its Gas Abatement Program. The report provides completion of the biological, alternative designs, physical sampling, and development of the numerical modeling portion of the program. The primary focus of the Corps' future activities in this program will be conducting model simulations for evaluating gas abatement alternatives for mainstem federal Snake and Columbia river hydro projects. In the future, the Corps' modeling work will be integrated with an ongoing effort by the interagency Transboundary Gas Group to develop a modeling tool which will characterize TDG production and analyze gas abatement alternatives at other mainstem hydro projects in other reaches of the Columbia River Basin in Canada and the U.S.
6. Installation of proven technologies, such as flow deflectors ("flip lips") on spillways, which provide significant reduction in gas saturation with small amounts of physical injury to fish, should proceed at all possible speed as an interim measure, regardless of decisions about future hydrosystem configuration (which likely will take more than 10 years to implement).
The ISAB recommends that gas abatement be considered in two time frames. First, the near-term time frame (less than 10 years) can include installation of proven technologies such as flow deflectors on spillways that do not currently have them. Some other modifications that are relatively inexpensive and effective could also be considered and used. Even if dams are breached or drawn down in the future, breaching or drawdown will not happen quickly and the benefits of installing gas abatement measures can provide interim benefits. If the dams remain, even if operated quite differently than at present, the near-term spillway modifications will be useful for the long-term as well.
7. The Corps should explore and evaluate all reasonable concepts for long-term gas-abatement solutions, but at a low level and subject to peer review as the evaluations progress and before prototype testing.
The Corps can, at a slower pace, consider all feasible options for gas abatement in the long-term (more than 10 years). A measured pace of engineering evaluations, possible prototype and biological testing, regulatory approvals for new devices, and systemwide gas reduction efforts using these technologies in combination with judicious system operation can be conducted over the next several years and be aided by periodic scientific and engineering peer review.
Summary of Comments: No written comments were received on this report.
Staff's Proposed Council Recommendations:
The Council concurs with the ISAB's recommendation that the Corps should continue implementation of its Gas Abatement Program as a high priority, and proceed with gas abatement to the lowest level practicable at reasonable cost. Short of "natural river" modifications to the hydro projects, spill remains the passage strategy that is the most "normative" in terms of the normal movement of salmon through the river system, and for this reason appears to continue to provide the greatest increment of survival of the in-river passage strategies. For this level of survival to be significant, however, depends in part on taking what actions we practically can to reduce the dissolved gas impacts of spill.
The Council strongly recommends the Corps' Gas Abatement Program for federal mainstem hydro projects should continue to be coordinated and integrated with the ongoing interagency Transboundary Gas Group effort to abate TDG on a systemwide basis. The goal of the Transboundary Gas Group is "to reduce systemwide TDG to levels safe for all aquatic life in the most cost-effective manner possible." Ongoing efforts by the Corps to synthesize the physical monitoring information in the form of gas generation and equilibration models of the hydrosystem will be valuable for developing an assessment tool to analyze alternative abatement technologies. Accordingly, the Corps' gas modeling work should be integrated with an ongoing effort by the Transboundary Gas Group to develop a modeling tool which will characterize TDG production and analyze gas abatement alternatives at other mainstem hydro projects in other reaches of the Columbia River Basin in Canada and the U.S. The long-term goal of the Corps, and other hydro project operators in the basin, should be to try to reduce TDG to levels that can achieve the 110% state and federal water quality gas standard. The region will be better able to accomplish this goal in the most cost-effective manner if it takes a systemwide approach to gas abatement instead of a dam-by-dam approach.
The Council also agrees with the ISAB conclusion that additional biological studies are not immediately necessary for continuing the gas abatement program. The Council recognizes there is much interesting, scientifically valid but topically diffuse biological research that will not assist the region in the near-term establish an optimal mix of spill and other passage routes for best salmon survival. The Council supports the ISAB conclusion that trying to justify a specific "safe" gas saturation level other than 110% on the basis of biological research is likely unattainable in a reasonable time frame or at a reasonable cost, and therefore such research is not needed at this time. Instead, proceeding with operational and structural gas abatement measures to achieve the lowest gas level attainable at a reasonable cost is preferable.
However, the Council does recommend that possible physical injury and mortality induced by alternative gas abatement structures should be evaluated prior to installation. The scientists point out there is evidence that even relatively proven technologies such as spill deflectors can induce some injury or mortality that may be comparable to that from other passage routes. Thus the relative risks to fish from spill with gas abatement structures should be compared to those of unabated gas supersaturation in the river, as well as to fish passage approaches other than spill, such as surface bypass or surface spill.
Finally, the Council recommends that gas abatement alternatives be considered in two time frames. First, within the near-term, or in the next few years, the Corps should explore all operational alternatives available to reduce TDG, as well as consider installation of proven technologies such as flow deflectors on spillways that do not currently have them. Other modifications that may be relatively inexpensive and effective should also be considered and utilized. Prior to installation of these technologies, however, physical modeling and/or biological evaluations should be undertaken to determine possible adverse impacts on adult fish passage and potential injury to juvenile fish.
At a slower pace, beyond 10 years, the Corps should consider all feasible options for gas abatement, including major tailrace and stilling basin modifications. A measured pace of engineering evaluations, possible prototype and biological testing, regulatory approvals for new devices, and systemwide gas reduction efforts using abatement technologies in combination with fully coordinated system spill operations should be conducted over the next several years. The longer term effort would be aided by periodic scientific and engineering peer review.
The state, federal and tribal fishery agencies, through the Columbia Basin Fish and Wildlife Authority, recently completed a comprehensive gas abatement implementation, research, monitoring and evaluation plan. The CBFWA plan is based on the ISAB report and recommends actions in the near-term, medium-term and long-term that appear to be compatible with the approach suggested by the ISAB and recommended here. The Corps, the SCT and Transboundary Gas Group participants are aware of the CBFWA dissolved gas plan, but it is not clear to what extent CBFWA intended it to guide Corps budget decisions as well as decisions by the Council and Bonneville on the use of the direct fund. The Council recommends that the Corps, the SCT and the Transboundary Gas Group expeditiously review the CBFWA gas plan.
Adult Fish Passage
Background on Adult Fish Passage:
Both the Council's Fish and Wildlife Program and the NMFS' Biological Opinion include a number of specific measures to improve survival of adult fish at mainstem Snake and Columbia river dams, including adherence to all spill and operating criteria at adult fish passage facilities and implementation of needed structural improvements. Both plans call on the Corps to leave juvenile fish screens installed for a longer period during the year to provide protection for adult salmon that might fall back through the powerhouse. The major measures called for in all salmon plans include: installation of automated fishway control systems; adult fishway modifications and improvements at McNary, The Dalles and Bonneville dams; evaluation of covering existing fish ladders, or alternative means to reduce fish ladder water temperatures; and improving the effectiveness of entrance attraction flows and fishway hydraulics, including improvements (and emergency back-up capability) in auxiliary water supply systems. Through FY 1999, over $6.5 million will have been spent on adult fish passage improvements or evaluations to improve adult passage, with additional funds earmarked for FY 2000.
The tribal plan recommends that the Corps, with fishery agency and tribal approval, finish structural assessments of all mainstem fishways and take necessary corrective actions, including improving attraction flows; installing additional pumps, gravity flow systems, automated systems and additional fish ladders; and modifying ladder exits to reduce adult fallback. In addition, the tribal plan calls for identification and implementation of structural remedies to reduce the incidence of adult shad in the fishways and to evaluate and implement new fishway designs that emphasize modifications to weirs, baffles and pools. These modifications should be based upon maximizing adult bioenergetic capacities by stimulating leaping, which tribal biologists maintain is more efficient than swimming in gaining elevation.
The tribal objective for adult passage is to reduce adult delay through the federal hydropower system by 50 percent by 2001, reduce adult upstream energy expenditures, and increase spawner distribution to upstream habitats. In the Snake River, the tribal focus on natural river drawdowns reduces or largely eliminates direct hydropower impacts on adult passage. At lower Columbia River dams, the tribal plan directs capital expenditures toward solutions of known problems such as fallback through the dams, and calls for increasing adult attraction flows and implementation of new emergency backup systems.
ISAB Findings:
The ISAB's technical evaluation of the Corps' adult fish passage program concludes (ISAB report 99-2) that "the subject of adult fish passage at [mainstem] Columbia River dams has not been adequately dealt with." In their report, the scientists state "there appears to be a widely held assumption in the region that problems with adult passage have, for the most part, been solved." On the contrary, the ISAB states "problems with adult passage deserve more attention." In particular, "many questions remain about the effects of delay or extra energy expenditure en route upstream on the ultimate ability of adults to spawn successfully."
The ISAB also notes the Corps' capital construction budget for adult fish passage improvements "addresses what we consider to be minor fixes and adjustments of existing systems." While the ISAB supports the Corps' sixteen planned dam-specific adult passage improvements, the ISAB also states that these improvements "probably are not sufficient to ensure that adult spawning migrations are unimpeded and completed with minimal mortality induced by passage." Their review shows that "questions associated with adult passage are not well resolved, and better information is needed." Accordingly, the ISAB calls for "additional evaluation, field research, and (probably) capital projects" to be implemented "before the problems of adult passage may be considered to be adequately addressed.
The scientists make five specific recommendations to improve the overall effectiveness of the adult fish passage program.
1. More emphasis should be placed on monitoring and evaluation of adult salmon numbers by the Corps, the Council, NMFS and the harvest management entities. 2. Include an annual operating project to determine the accuracy and precision of the counts of adult salmon passing the dams. Install PIT-tag detectors for adults at each project to provide data for estimates of survival in upstream passage, and to adjust the counts. 3. Critically evaluate sources of error in estimation of escapement to spawning grounds and hatcheries. 4. Support research to record [water] temperatures experienced by adults during upstream migration. 5. Consider reestablishing a bioengineering test facility for adult fish passage in the Columbia River Basin where engineering designs for passage improvement can be tested in full-scale [prototypes] with adult salmon. Fish behavior is a critical element in fish passage design and it cannot be ignored.
Summary of Comments:
To date, no written comments have been received by the Council on ISAB report 99-2.
Staff's Proposed Council Recommendations:
The Council concurs that correction or prevention of adult passage problems deserve more attention that they have received. Research is needed to address the effects of delay or extra energy expenditure en route upstream past the eight federal hydro projects on the ultimate ability of adults to spawn successfully.
Specific measures to improve adult fish passage through the hydropower system should try to bring the cumulative conditions for passage closer to what the fish likely experienced in pre-dam conditions, i.e., examine what the normative condition might be. Although the current design of adult fishways has considered the adaptation of adults to upstream movement through reservoirs and past large dams, much remains to be learned. This is reflected in continuing modifications of fishways involving capital construction costs and improvements in fish ladder attraction flows. The Corps should also consider innovative measures, such as inducing upstream attraction flows in forebays or providing cooler water taken from depth, for testing at selected dam sites. Important passage criteria for the adult fish passage program should be to minimize the delay and expenditure of energy by adults passing the hydro projects. Providing uninterrupted upstream passage at each individual fishway and minimizing fallback at each dam are necessary to meet these criteria.
Accordingly, the Council agrees with the ISAB recommendation that the region evaluate the feasibility of constructing a regional fisheries engineering research facility in the basin, as also called for in all three salmon recovery plans. Construction of such a facility in the Pacific Northwest would allow both engineering and biological studies to be conducted, focusing on experimental juvenile and adult fish passage structures and improvements incorporating elements of fish behavior. Presently there is no such research facility in the basin, and so engineering model studies are conducted at the Corps' Waterways Experiment Station in Vicksburg, Mississippi. Construction of a regional bio-engineering research facility should allow for a) full state, federal and tribal participation in development of fish passage alternatives at substantial savings in travel costs, and b) biological and fish behavioral evaluations of passage improvement designs using Columbia Basin salmonid and other basin migratory fish stocks. The ISAB concluded that further research on fish behavioral cues is key to improving the performance of both upstream and downstream fish passage facilities. These cues can only be identified and better understood when fish passage designs are tested with real migratory fish.
In addition, more research needs to be done on the effect of temperature on adult salmon. Specifically, more research or monitoring is needed in the following areas:
- Research to record temperature histories of adult salmon during migration. Technology is available to record the temperatures experienced by adults during migration. Such studies would be valuable additions to our understanding and preparation for annual operational actions.
- Research to identify, enhance and protect existing thermal refuges, if found, for upriver migrants.
- Include an annual monitoring program to measure the ambient temperatures experienced by adults in the mainstem hydroelectric system. This would include annual monitoring of a) the temperatures in the fishways, b) temperatures in the reservoirs, and c) the degree-days experienced by adult salmon during passage through the hydrosystem. These monitoring programs are critical for all summer and fall migrating salmon stocks, but they may also be important for spring migrants.
Finally, the Corps should include an annual operating project to better determine the accuracy and precision of adult salmon passing the dams. Conservative correction procedures or factors for adult dam counts should be developed based on radio-tracking information or adult PIT-tag detectors. Adult PIT-tag detectors should be installed at more mainstem dams. Annual radio-tracking or PIT-tagging of adults across species will be necessary to estimate numbers of fish passing upstream through navigation channels and falling back through juvenile bypasses, spillways and navigation locks. Adjustments in counts will likely need to be made on an annual basis.
The ISAB recognized that the problems in dam passage counts that it identified become magnified in the way the fishery managers use dam counts to help determine exploitation rates in harvest management. The scientists concluded that "it is doubtful that they [the dam counts] are sufficiently reliable" for the purposes of the harvest management entities. They recommended that the fishery managers "[c]ritically evaluate sources of error in estimation of escapement to spawning grounds and hatcheries" and that "escapement goals and estimates, along with estimates of allowable harvest should include safety factors, if runs are to be rebuilt." The Council strongly concurs with that recommendation.
INDEPENDENT ENGINEERING REVIEW OF CORPS' CRFM PROGRAM
Background
One of the major policy issues identified in the scope of work as part of the Council review of Corps of Engineers' (Corps) mainstem fish passage capital construction program is "What means are available to obtain independent engineering review of the Corps' engineering design, scheduling, cost estimation and construction practices for mainstem capital fish passage improvement projects?" Put another way, are there efficiencies and cost savings that can be effected both in the design and installation of mainstem fish passage facilities? This section of the report explores the Corps' engineering review processes to identify ways to further improve fish passage project design and function while helping to control or reduce project costs, maintain schedules and enhance oversight.
To address this issue, Council staff met several times with representatives from engineering consulting firms in Portland to scope and refine this issue. In addition, the Council's Fish and Wildlife Committee has had several discussions of this issue with Corps of Engineers' representatives during 1998.
In addition, an issue paper was prepared reviewing the Corps' existing processes for independent technical/engineering review, value engineering and project partnering concepts, including suggestions, if any, to improve such processes. Over the last three years, the Corps has spent an average of about $ 85million of Congressionally-appropriated funds to implement its Columbia River Fish Mitigation Program (CRFM Program). The overall objective of these engineering review processes is to improve fish passage project design and function while helping to control or reduce project costs, maintain schedules and enhance oversight.
Background information was received on this issue from both engineering consulting firms and Corps of Engineers staff. The consultants provided information on current engineering industry review standards and processes, and how these processes are used to provide independent review of capital construction projects for clients. In addition, they provided insight on where Corps review processes may diverge from industry norms.
The Corps identified and provided detailed information on three different review processes it utilizes currently to provide quality control in the review of engineering products (including design memoranda, plans and/or specifications, engineering cost estimates, etc.) prepared for the mainstem fish passage capital construction program. These three processes, Value Engineering, Technical Review and Project Partnering, are currently applied to all Corps decision and implementation documents whether prepared in-house by Corps engineers or by private consulting engineers. These review processes, as used by the Corps and others, are described in more detail below.
Value Engineering
The first review process used by the Corps is called value engineering (VE). VE is an engineering review process where a small team of independent, objective and qualified engineers evaluates the initial design work, cost estimates, and functionality of a project developed by the design team for a specific project or process. It is used by the Corps (or clients of private consultants) to improve project efficacy and reduce costs. The objective of a VE study is to maintain the required project function at a minimum of cost, without sacrificing the necessary quality of the end product.
Value engineering is a standard and accepted engineering review practice that is used extensively in the private sector and by federal, regional and local governmental agencies including the Corps of Engineers, U.S. Department of Transportation, U.S. Bureau of Reclamation, U.S. Environmental Protection Agency, Tri-Met and the City of Portland, among others. The VE concept originated in the 1940s at the General Electric Company; the Corps initiated its own VE program in 1964, and has been implementing its version of VE for 34 years. Value engineering has national and international standards, including training and certification of both VE engineers and VE team leaders.
In the private sector, VE is typically used in the following manner. A "client," such as the City of Portland, contracts with an engineering consulting firm to design a particular construction project. Once the project design is at the 30 percent completion stage, the City hires a different engineering firm to perform VE on the preliminary design. The second firm then works with the design firm to analyze and incorporate the design changes and cost savings identified in the VE study, as needed.
The following questions and answers are intended to provide additional background information on the VE process.
What is a value engineering study?
A VE study is an assessment of a proposed engineering design solution of a project to determine whether alternative design options or revised project requirements will lead to design options for that project which are more practical and feasible. A VE study of a project is typically conducted at the 30 percent (preliminary) engineering design phase to allow investigation of alternative design options before a project progresses into the more detailed engineering plans and specifications phase.
What criteria are used by the Corps to trigger a VE study?
Corps policy requires a formal VE study on all construction projects with an expected construction estimate of $2 million or more, and on supply, service and O&M projects with a cost estimate exceeding $1 million. The Division Commander must approve exceptions to this requirement. For comparison purposes, VE reviews for the City of Portland are mandatory for all construction projects with an estimated construction cost of $5 million or more.
A VE review is a process used to determine if a VE study is warranted on a project. The Corps states a brief VE review is done on projects over $2 million to assure that a VE study should be performed. If the Corps determines that a VE study is not warranted, the project file is documented stating the reasons. A VE review may also be done on Corps projects estimated to cost under $2 million to determine if a VE study is warranted. Corps VE reviews typically are accomplished informally by experienced Corps VE staff.
What are the steps in a typical VE study process?
The steps in a typical VE study process include: 1) decide what project is going to be designed; 2) select the design team and begin the engineering design process; 3) at about 30% completion of the design phase, an independent VE team leader and team are selected and a VE study of the project is performed; 4) the VE team reviews the preliminary design drawings and cost estimates and holds a workshop to discuss the 30% plans and specifications with the design team; 5) the VE team develops its own list of engineering assumptions, design alternatives, and estimated cost savings and submits its report to the project owner and the lead design engineer; 6) the design team engineers review and develop their responses to VE findings, issues and recommendations and submit their responses to the VE study team leader; 7) the design team responses are reconciled by the VE study team working with the design team; and 8) an action plan for future design work on the project is then prepared from the final VE study report.
How long does it take to complete a VE study? How much does a VE study cost?
Based on information provided by the Corps, it usually takes between 3-5 working days to complete a Corps VE study. Depending on the detail and scope of the review process, VE studies for recent CRFM projects range in cost between about $10,000 and $76,400, for projects budgeted from $175,000 up to $28 million. For comparison purposes, VE was performed on the Portland area westside light-rail construction project (excluding the tunnel) in 10 working days at a cost of $75,000, for a project budgeted at $300 million.
What is the Corps' overall VE cost savings goal?
Both Walla Walla and Portland Districts' VE savings goal is to achieve 6 percent savings annually on each District's entire construction general budget. The Walla Walla District also has a goal of achieving a 10:1 net return on investment for its VE studies. According to the Corps, this savings goal has been met or exceeded in 4 of the last 5 years in the Walla Walla District, and in each of the last 5 years in the Portland District.
According to the engineering consulting firms contacted, the private sector usually achieves VE savings ranging from 8 to 12 percent per project. One consulting firm quoted an average VE savings of 13 percent.
Although the Corps has indicated large VE cost savings in its Program, it is unclear where the savings on some projects may have been achieved. For example, the John Day Dam smolt monitoring facility was originally budgeted by the Corps to cost about $8 million, but due to inaccurate foundation test borings, the project cost jumped by an additional $8 million. Also, the juvenile fish bypass improvements at Bonneville Dam first powerhouse, including the outfall, were originally budgeted at about $46 million, but omission of contingency costs and inaccurate project cost estimates found just prior to awarding the contract escalated these costs to $62 million, delaying some of the work into out-years.
What is the difference between VE during design and VE during the construction phases of a project?
VE can be used to evaluate the design or construction phases of a project or it can also be used to evaluate a process . In a VE review during the design phase, it is an assessment of a proposed engineering design solution of a project to determine whether alternative design options or revised project requirements will lead to design changes for that project which are more practical and feasible. In the construction phase, in a typical Corps construction contract, there is a VE Change Proposal clause. In essence, this clause allows the construction contractor to propose changes to the contract that provide the same function as the original contract, but result in an "instant" contract savings. The Corps states these changes are typically substitution of less expensive materials. Usually, VE methodology is not used, and it is difficult to make major changes that have significant cost savings during construction.
What are the advantages of conducting VE studies?
Besides the obvious advantages of improving efficacy and incurring significant cost savings in designing and constructing a project as noted above, additional value is realized by reducing project risk, project schedule slippage and cost overruns. As project risk is reduced, the level of contingency cost assigned to a project can also be reduced. Private engineering consulting firms maintain that contingency costs in the 10-20 percent range are typical during the preliminary design stages of a project. However, as a project moves through detailed design and is ready for construction bid, contingency costs should decrease. Industry standards typically identify contingency costs of less than 10 percent. High contingency costs in the 40-50 percent range are an indication that a project has not been well planned or understood. Contingency costs for Corps projects vary widely; Corps staff provided figures ranging from 6 to 25 percent. The Corps should make efforts to maintain its contingency costs within a range similar to that of the private sector.
What teams are used to conduct Value Engineering studies?
VE reviews are usually conducted by a team of independent, certified value engineers from a variety of engineering disciplines. A VE team typically consists of a certified VE team leader, who assembles the team from engineers with the appropriate training/expertise necessary to review the proposed project. This could include engineers experienced in operations, construction, project cost estimation, as well as all the major engineering design disciplines.
The Corps uses a variety of teams, including in-house engineers, private engineering consultants, Office of the Chief Value Engineering Study Team (OVEST), or any combination of experienced professionals having specific knowledge in the type of project being evaluated. The Corps maintains that project customers, users and other stakeholders should be included in the VE study, if feasible. A VE study is facilitated by a team leader, and the results of the VE study are recorded in a VE report on the project, which typically averages 30 to 50 pages in length. The Corps has provided background information on VE studies that have been accomplished on CRFM Program projects by both the Walla Walla and Portland Districts over the last 5 years.
Technical Review
The second process used by the Corps, called technical review, is an independent review of an engineering product by a team of technical experts. Technical reviews are conducted by Corps District personnel as part of the Corps' normal business practices on all planning, environmental and engineering design products produced by the Planning and Engineering Division, which includes all CRFM Program work. Technical review is a relatively new practice required by the Corps as part of its quality control procedures. It is typically conducted at the later stages in the project design phase, such as at the 90 percent completion level. It is used to confirm the proper selection and application of established criteria, regulations, laws, principles, and professional engineering procedures have been applied to a project to ensure a quality product is produced. Technical review is also intended to confirm the constructability and effectiveness of the final engineering product, as well as the use of clearly justified and valid assumptions for a project that are consistent with established Corps policy.
Technical reviews conducted by the Corps are performed by teams comprised of various resource options (or combinations thereof) as follows: a) in-house (District) personnel; b) Division office personnel; c) other District/Division personnel; d) Designated Centers of Expertise within the Corps; e) other sources throughout the Corps including labs, research facilities, etc.; and f) engineering consultants or industry experts. Selection of a technical review team depends on the nature of the work to be evaluated, staff availability and schedule. The technical review team is usually comprised of professional engineers having the same design disciplines as the project design team, i.e., engineers with training/expertise in hydraulic, structural, mechanical, electrical, geotechnical, etc. disciplines. Technical review includes both an in-progress review of a project as well as a review of the final product.
The Corps maintains that whenever in-house staff is used for a technical review, independence of the review is assured by using team members that have not been involved in the project development or design process. Technical review team findings are typically documented in writing by the Technical Review Team leader and supplemented by signature concurrence of the District's senior management. The Technical Review Team leader forwards the review findings and comments on the project design to the design team leader. The design team leader, together with the design team, must then respond to all comments prepared by the technical review team. This is typically a 3-week process. At the completion of this process, a technical review certification document is prepared. This document certifies that a technical review has been accomplished for a particular project. Attached to this document are all of the issues that were raised and resolved during the technical review process.
Most large capital construction projects, public or private, call for some version of technical design review at the 90 percent completion point of the design phase.
Project Partnering
The concept of partnering was developed by the Corps to save costs on projects by improving communication and reducing conflict between the project owner/engineer and the architectural/engineering firm or construction contractors. Partnering is a process whereby the stakeholders in an endeavor agree to set personal interests aside for the benefit of the project as a whole.
It is not a contractual or legal agreement, rather it is a relationship-based process. Each stakeholder in a project strives to understand the interests of the others and all seek a mutually acceptable outcome. In essence, it creates a means to resolve conflicts through development of a partnering agreement as opposed to using litigation. It is a successful technique and one the Corps uses routinely.
Partnering has focused on relationships between the District and AE contractors during the design phase and between the District and construction contractors during the construction phase. As the Corps Operations Division is typically the "operator" of completed civil works projects, that division also participates in the partnering process. When AE firms are involved in the design of a project, they are also included in the partnering process during project construction. Rather than the fishery managers, Corps personnel responsible for coordination and communication with the regional fishery agencies and tribes represent the interests of the resource in this process.
Once a project enters the construction phase, partnering allows early visibility of potential schedule changes and cost impacts and the opportunity to pursue alternatives that may mitigate for those changes or impacts. However, project partnering does not waive nor supersede contractual requirements or remedies. If the construction contractor is entitled to additional compensation or time under the provisions of the contract, the Government is obligated to make an equitable adjustment to the contract.
The Corps' experience with partnering confirms its positive benefits. Litigation, with its expense, time and risks, has been avoided and contracts are typically completed to the satisfaction of regional stakeholders. In numerous cases, partnering has offered the opportunity to develop alternatives that have mitigated significant delays and cost growth in contract performance.
Summary of Comments Received on Issues
Comments to issue paper 98-6 were received by a number of parties. The Corps asserts that "getting early regional agreement on scopes and schedules for construction processes is critical. Unfortunately, participation [in the Corps' regional coordination process] has been inconsistent and often lacking. Consequently, requests for late stage changes in scope and/or design have occurred frequently." This results in project cost increases and schedule slippages. The Corps recommends "the most effective way to minimize cost increases on fish projects is to emphasize up-front coordination with the goal of minimizing scope and direction changes" and "the most effective way to alleviate this problem would be to involve engineers from the fishery [agencies and tribes] perspective in the [fish project engineering design] discussion."
On the issue of independent technical review, the Corps states it "is very committed to the assurance of the highest technical quality both in the designs we develop and in the projects we build" and "this independent review requirement has always been a key part of the Corps Review Process." However, the Corps admits that "changes to the independent review process [in 1995] to save money and time placed responsibility for the Independent Technical Review directly on the Districts instead of the Division [where it historically had been]." The Division office now has "a quality assurance responsibility to ensure that the integrity of the independent review process is maintained."
On the value engineering process, the Corps states the "key to successful application of a value [engineering] study is the skills and experience of those (on the team)…it is most advantageous if either the team leader, or a team member, [has] responsibility for implementation of the approved value proposals at study completion." Thus, the Corps maintains "the Value Engineering Team needs to be composed of experts, including biologists and other scientists, as well as engineers involved in fish facility design…this group needs an understanding of regional desires and acceptable fish passage criteria."
In its comments, BPA states "the Corps' VE savings goal could be raised so that it more closely matches the private sector, i.e., 8-12% instead of the current 6%." BPA also points out "appropriated or ratepayer funds are paying the vast majority of work in the Columbia River Basin…the option of paying regional fishery agency and Tribal representatives to charge their time against a particular project during its development … would only exacerbate the current problems associated with cost-effective implementation of the Fish and Wildlife Program." From BPA's perspective, the region needs to "reach consensus on and implement a specific set of performance criteria related to downstream passage of juvenile salmonids and upstream passage of adult salmonids" before real cost efficiencies in the CRFM Program can be attained.
The Council also received detailed written comments from the International Federation of Professional and Technical Engineers (IFPTE) in San Francisco, representing professional and non-supervisory engineers in the South Pacific Division of the Corps of Engineers. The IFPTE "concurs with the view that the Corps' current technical review process is not truly independent." Their comments state that "Corps restructuring was accomplished in 1995 in response to Congressional pressure to streamline the agency with the intention of cutting overall costs and project review and processing times." This restructuring was done by "de-emphasizing the regional Division offices through stripping of functions and downsizing: in particular, this meant that technical review functions were pushed down to the Districts for self-review and the 'policy' review functions were formally given to Washington [D.C.]." Therefore, "the term 'independent' is not truly applicable … it is not a reality." "At the present time, there is only one level of technical review (or plan check) within the Corps - at the District level … this new multilevel [review] process is likely to cause further delays and less predictability in Corps projects." In summary, according to these Corps employees, "the Corps' capability to do independent reviews has been organized out of existence: a result that jeopardizes the design, construction and operation of Corps public works facilities."
The IFPTE also submitted a position paper concerning civil works technical reviews. In this paper, dated September 1, 1994, an analysis was performed on construction cost growth associated with engineering design deficiencies of military design projects undertaken by the South Pacific Division from 1987 through 1994. It was during this period that technical reviews of in-house (District) designs was taken away from the Division office and given to the Districts. This analysis shows "a 2% ($94.4 million) cost growth upswing [nationwide associated with design deficiencies of military design projects] experienced in 1993, the first year [when] Division level technical reviews [did not] take place." The IFPTE position paper goes on to recommend "this same technical review transfer [to the Districts] mistake should not be repeated with the civil works funded program."
The IFPTE also submitted, as part of its comments, an American Society of Civil Engineers (ASCE) policy statement adopted in 1993 concerning project peer review. This policy statement states "project peer review is a separate, important step in the design process … to provide an evaluation of design concepts and management to meet performance objectives. Reviews by teams or individuals within the project design team are not project peer reviews" [emphasis added] and that "project peer review is an extra precaution that can … add a measure of increased confidence that the design is adequate." In its policy statement, the ASCE recommends that, "as a standard practice, federal regulatory agencies seek consultation from outside 'independent' technical 'experts' through a formal peer review process."
Staff's Proposed Council Recommendations
1. How to obtain regional agreement on project scope and schedule early in the process. Annual prioritization of, and identification of biological criteria for, CRFM Program projects is the subject of extensive discussions between the Corps and regional fishery agency personnel in regional forums such as the System Configuration Team (SCT) and the Corps' Fish Facility Design Review Work Group (FFDRWG) which focus on these issues, respectively. Once a particular project is identified and selected for funding and execution, usually in the SCT forum, the Corps asserts that lack of regional agreement or buy-in on a project's scope and/or schedule can be a major stumbling block during the design process. As indicated above, the Corps maintains that considerable time can be lost and increased design costs incurred because regional interests fail to participate fully in the FFDRWG and SCT forums and/or continue to revise the project scope or schedule during the design phase. Unfortunately, many of the fish and wildlife management entities do not have the resources or the appropriate engineering/technical staff to participate in the FFDRWG and SCT forums in a meaningful way, if at all. Few, if any, have enough engineers on staff or the resources to employ more on a regular basis. This inability to participate on an equal basis with the Corps has frustrated many of the fish and wildlife managers; and the lower river Treaty tribes are no longer active members of the NMFS Regional Forum process, including the SCT. The Corps proposes to use the Charrette process to address this problem. This process attempts to seek consensus among regional stakeholders in establishing a project's scope and schedule before beginning project design. Under this process, all stakeholders in the region would be more fully involved in developing the initial project scope and schedule. This should result in reducing the lost time and cost of design caused by revising the scope and schedule during the design process. Under the Corps proposal, once a CRFM project has been identified for design, regional interests could enter into a "partnering agreement," which would attempt to develop mutually agreed-upon project objectives, identify each parties' objectives, at what level various conflicts will be resolved, and how to communicate progress on the project. Such agreements have the potential to enhance communication among parties, provide a forum to resolve disputes, and would allow the regional oversight and technical coordination teams (the SCT and FFDRWG) and design teams to better understand issues that arise in a timely manner. A disadvantage to this process is that it requires additional participation of limited agency staff resources and a greater time commitment from all regional parties in the conceptual development of projects. To obtain greater agency participation and buy-in in the early phases of project development, and if lacking the technical expertise, the Council suggests funding be provided for regional fishery agency and tribal representatives in the initial project scoping process (FFDRWG) similar to other regional coordination funding provided by BPA. Such regional coordination costs could be offset by potential savings in design costs and schedule changes due to additional agency and tribal participation in the initial phases of project development. 2. How to provide truly independent engineering review of Corps CRFM projects.
As stated above, both the VE and technical review teams should be comprised of a small group of independent, objective and qualified engineers to evaluate the work done by design engineers on a specific project. It is recommended by numerous commentors the key to successful VE and technical reviews is to have a reviewing team that is not influenced by the policies or organizational constraints of either the design team nor the organization. Not only does the reviewing team need to feel free to test all of the engineering assumptions being used by the design team, but it also should be outside the institutional influence and policies of the design team's organization.
The Corps maintains that whenever in-house staff is used during a VE or technical review, independence of the review is assured by using team members that have not been involved in any way in the project development or design phases. However, based on information provided by two of the Corps Districts concerning their recent VE studies, most (58-78 percent) of the VE team members have been in-house Corps personnel from the Portland and Walla Walla Districts, and another 19-24 percent were in-house Corps VE officers or from the Corps' OVEST office. In other words, the vast majority of recent VE team members have been Corps of Engineers personnel. In the Portland District VE studies, only 17 percent of VE team members were selected from outside the Corps or from engineering consulting firms, while only two team members in all the Walla Walla studies were non-Corps - one from the Bureau of Reclamation and the other from a private engineering firm.
The Council recommends, to ensure independence in VE and technical review processes, that the Corps make concerted efforts toward increased use of review teams from private engineering firms to conduct VE and technical reviews of Corps fish passage projects. For example, when Corps engineers have designed a project, the Corps should make efforts to contract with private engineering firms for up to half of its scheduled VE and technical reviews, particularly on high profile or controversial fish passage projects. Greater use of private engineering review teams would help insulate the Corps from criticism by outside parties when problems arise with fish passage project designs, costs or schedules. On the other hand, if a private sector engineering firm is responsible for the design of a Corps fish passage project, independent review teams from either the Corps or the private sector could conduct the scheduled VE and technical reviews. This proposal has the advantage of not requiring the Corps to develop a revised contracting process, while still assuring independence of the VE and technical review teams.
