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    		REPORT TO THE SUBCOMMITTEE
    		ON FISHERIES AND WILDLIFE
                CONSERVATION AND THE
                ENVIRONMENT
                COMMITTEE ON MERCHANT MARINE
                AND FISHERIES
                HOUSE OF REPRESENTATIVES

                       COASTAL ZONE
                       INFORMATION CENTER
                Improved Federal Efforts Needed
                To Equally Consider Wildlife
                Conservation With Other Features
                Of Water Resource Developments
                                          B-118370

                BY THE COMPTROLLER GENERAL
                OF THE UNITED STATES

       HC
       110
       .E5
       U5485                                                  MARCH 8,1974
       1974

                                                                      SEP 13 1974
                               COMPTROLLER GENERAL OF THE UNITED STATES
                                        WASHINGTON. D.C. 20548

               B-118370                       U    DEPARTMENT OF COMMERCE NOAA
                                              COASTAL SERVICES CENTER
              PrOPerty of CSC Library         2234 SOUTH HOBSON AVENUE
                                              CHARLESTON , SC '29405-2413

               The Honorable John D. Dingell
               Chairman,.Subcommittee on Fisheries and
                 Wildlife Conservation and the Environment
               Committee on Merchant Marine and Fisheries
               House of Representatives

               Dear Mr. Chairman:

                    This is our report on improved Federal efforts needed
               to equally consider wildlife conservation with other features
               of water resource developments. We made our review pursuant
               to your request.

                    As your office requested, we did not obtain written com-
               ments on this report from the agencies included in our re-
               view. However, we did discuss the matters presented in this
               report with agency officials.

                    We do not plan to distribute this report further unless
               you agree or publicly announce its contents. We want to di-
               rect your attention to the fact that this report contains rec-
               ommendations to the Secretaries of Commerce, the Army, and the
               Interior, and the Director, Office of Management and Budget.
               As you know, section 236 of the Legislative Reorganization Act
               of 1970 requires the head of a Federal agency to submit a
               written statement on actions he has taken on our recommenda-
               tions to the House and Senate Committees on Government Opera-
               tions not later than 60 days after the date of the report and
               to the House and Senate Committees on Appropriations with the
               agency's first request for appropriations made more than 60
               days after the date of the report. Your release of the report

            9-7

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             B-118370

             will enable us to send the report to the Secretaries, the
             DirectorP and the four committees for the purpose of setting
             in motion the requirements of section 236.

                                           Sincerely yours,

                                           Comptroller General
                                           of the United States

                                           2

                                             GLOSSARY

                 Anadromous            Fish which spend part of  their life
                                       cycle in freshwater and another part in
                                       saltwater.

                 Channelization        The practice of deepening, widening,
                                       straightening, or clearing the existing
                                       channels of rivers and streams for
                                       drainage, flood control,navigation, or
                                       erosion control.

                 Conservation          includes both the mitigation and enhance-
                                       ment measures necessary to conserve and
                                       develop wildlife resources.

                 Development           Any alteration or modification of water
                                       resources through,Federal or federally
                                       assisted projects, Corps of Engineers
                                       permits, or Federal Power Commission
                                       licenses.

                 Development           Federal agencies, except wildlife agen-
                   agencies            cies, responsible for planning, approv-
                                       ing, or constructing water resource
                                       developments. These agencies are also
                                       referred to as water resource develop-
                                       ment agencies.

                 Enhancement           The improvement or development of wild-
                                       life or its habitat as a result of a
                                       water resource development.

                 Estuary               An area which includes all or part of the
                                       mouth of a navigable or interstate river
                                       or stream or other body of water having
                                       unimpaired natural connection with the
                                       open sea and within which seawater
                                       is measurably diluted with freshwater
                                       derived from land drainage.

                 Estuarine             Those lands within estuaries which are
                   wetlands            covered with shallow and sometimes
                                       temporary or intermittent waters.

              Federal projects      All Federal or federally assisted water
                                    resourcedevelopments.

              Mi tigation           The prevention or replacement of losses
                                    or lessening of damages to wildlife re-
                                    sources due to water resource develop-
                                    ments.

              Section 10            Form of permission granted by the Corps
                permits             of Engineers to those parties who wish
                                    to do work in the Nation's navigable
                                    waters which will modify those waters.
                                    Modifications include dredging and con-
                                    struction of facilities, such as bulk-
                                    heads and wharves. The Corps gran-cs
                                    permits under authority of the Rivers
                                    and Harbors Appropriation Act of 1899
                                    (33 U.S.C. 403).

              Separable costs       The additional or incremental costs nec-
                                    essary to include a purpose in a water
                                    resources project.

              Small watershed       These are multiple-purpose projects,
                projects            authorized under the Watershed Protec-
                                    tion and Flood Prevention Act, which are
                                    used for such purposes as reducing floods,
                                    enhancing fish and wildlife resources,
                                    supplying water, providing recreation
                                    and other benefits in watershed areas
                                    no larger than 250,000 acres.   The pri-
                                    mary responsibility for administering
                                    the program rests with the Soil Conserva-
                                    tion Service (SCS), Department of Agri-
                                    culture.

              Wildlife              Birds, animals, and fish and supporting
                                    habitat.

              Wildlife              Denotes fish, game, or other wildlife
                agencies            agencies at both the Federal and State
                                    level.

              Wildlife              Includes both wildlife and the habitat
                resources           upon which wildlife depends.

                  108 review          Refers to SCS's Watersheds Memorandum
                                      108, dated February 4, 1971, which pro-
                                      vides for reviewing approved watershed
                                      work plans that include stream channel
                                      improvements not yet installed and
                                      classifying the-degree of environmental
                                      impact of each into one of three groups:
                                      Group 1--minor or no known adverse ef-
                                      fect; Group 2--some adverse effect;
                                      Group 3--serious adverse effects. The
                                      SCS review is done in cooperation with
                                      State and Federal wildlife agencies.

                                         C o n t e n t s
                                                                             Page

                 DIGEST                                                         1

                 CHAPTER

                    1      INTRODUCTI ON                                        5
                               The Fish and Wildlife Coordination Act           5

                    2      NEED TO IMPROVE FEDERAL EFFORTS TO EQUALLY
                             CONSIDER WILDLIFE CONSERVATION WITH OTHER
                             FEATURES OF WATER RESOURCE DEVELOPMENTS            8,
                               Need for more complete consultation and
                                  studies on wildlife effects                  15
                                    Lack of consultation and adequate
                                      study on section 10 permits              16
                                    Wildlife aspects of federally funded
                                      projects not adequately studied          16
                                    Wildlife agencies not always con-
                                      sulted on modifications                  23
                               Recommendations on wildlife studies
                                  should be timely and more specific           24
                                    Recommendations were not specific          25
                                    Detailed reports not available for
                                      project approval                         26
                               Need for criteria to determine the miti-
                                  gation and enhancement measures              29
                                    Criteria is needed for determining
                                      mitigation measures                      29
                                    Problems in achieving   wildlife
                                      enhancement                              32
                               Mitigation measures not always recom-
                                  mended on SCS projects                       33
                               Wildlife conservation recommendations
                                  should be jointly planned                    34
                               Followup necessary to determine whether
                                  accepted wildlife conservation meas-
                                  ures are being implemented                   36
                               Need for the wildlife agencies to agree
                                  on coordination roles and responsibil-
                                  ities                                        39
                                    Impact of Reorganization Plan No. 4
                                      on the Fish and Wildlife Service's
                                      functions                                39

                                                                          Page

               CHAPTER

                                 Efforts to agree on roles and
                                    responsibilities                       41

                  3      CONCLUSIONS A14D RECO@ZIENDATIONS                 43
                             Conclusions                                   43
                             Recommendations to the Secretaries of
                               the Army, Commerce, and the Interior        45
                             Recommendation to the Director, 014B          ..45

                  4      COMMENTS ON PROPOSED LEGISLATION                  47

               APPENDIX

                  I      Letter dated March 16,. 1972, from the Chair-
                           man,, Subcommittee on Fisheries and Wildlife
                           Conservation and the Environment, House of
                           Representatives                                 49

                  II     Agencies and programs selected for review
                           and locations visited                           51

                 III     Water resource developments selected for
                           review                                          53

                  IV     Estimates of BSF&W--NMFS workload., funding,
                           and manpower needs for Fish and Wildlife
                           Coordination Act and related environmental
                           work                                            54

                                        ABBREVIATIONS

               AEC       Atomic Energy Commission

               BCF       Bureau of Commercial Fisheries

               BSF&W     Bureau of Sport Fisheries and Wildlife

               'EIS      environmental.impact statement

               EPA       Environmental Protection Agency

                     FPC      Federal Power Commission

                     GAO      General Accounting Office

                     NMFS     National Marine Fisheries Service

                     NPDES    National Pollution Discharge Elimination System

                     OMB      Office of Management and Budget

                     SCS      Soil Conservation Service

                COMPTROLLER GENERAL'S REPORT TO THE         IMPROVED FEDERAL EFFORTS NEEDED
                SUBCOM41TTEE ON FISHERIES AND               TO EQUALLY CONSIDER WILDLIFE
                WILDLIFE CONSERVATION                       CONSERVATION WITH OTHER FEATURES
                AND THE ENVIRONMENT                         OF WATER RESOURCE DEVELOPMENTS
                COIVITTEE ON MERCHANT                       B-118370
                AND FISHERIES
                HOUSE OF REPRESENTATIVES

                D I G E S T

                WHY THE REVIEW WAS MADE                      --Bureau of Reclamation and the
                                                               Bureau of Sport Fisheries and Wild-
                At the request of the House Sub-               life (BSF&W), Interi-or;
                committee on Fisheries and Wildlife
                Conservation and the Environment,            --Federal Power Comliiission;
                GAO reviewed implementation of sec-
                tions 2 and 3 of the Fish and Wild-          --Soil Conservation Service.  (SCS);
                life Coordination Act.                         and

                The act provides that wildlife con-          --National Marine Fisheries    Service
                servation receive equal considera-             (NMFS), National Oceanic and At-
                tion and be coordinated with other             mospheric Administration.
                features of federally funded or li-
                censed water resource developments.          FINDINGS AND CONCLUSIONS

                GAO reviewed 28 water resource de-           Section 2 of the act generally pro-
                velopments typical of those which            vides that:
                have had a major impact on wildlife
                in three geographic areas: the               --Federal development and permitting
                Atchafalaya River Basin in Louisiana,          agencies consult with Federal and
                the Cape Fear and adjoining Neuse              State wildlife agencies at the
                River Basins in North Carolina, and            earliest stages of planning for or
                the Columbia River Basin in the                involvement in water resource de-
                Pacific Northwest.                             velopments.;

                Developments included projects    that       --Wildlife agencies study effects of
                were federally funded or permitted             proposed developments and make
                under Federal law for work in'the              recommendations for protecting and
                Nation's navigable waters which                improving Wildlife resources.
                would modify those waters..
                                                             --In the case of federally funded
                Agencies covered in GAO's review               projects, development agencies in-
                were the:                                      clude in any report to the Congress
                                                               at the time of project authorization
                --Corps of Engineers (Civil Func-              those measures they believe are justi-
                  tions), Army;                                fied for wildlife conservation.

                 Tear Shee Upon removal, the report
                 cover date should be noted hereon.

                 Section 3 provides that adequate         --The Pacific Northwest's Columbia
                 provisions, including acquisition of        River Basin, rich in wildlife, has
                 lands and waters, be made at water          had its water resources developed
                 resource developments for wildlife          extensively for power, navigation,
                 conservation.                               flood control, irrigation, and
                                                             other purposes.
                 Inrproved FederaZ coordination
                 efforts needed                           About 62 percent  of the Columbia
                                                          River tributaries are inaccessible to
                 Water resource development and wild-     salmon and steelhead trout because
                 life agencies need to improve their      of dams, and about 870,000 acres,
                 efforts to equally consider wildlife     much of which was big game habitat,
                 conservation with other features of      has been inundated by reservoirs.
                 water resource developments.
                                                          More wildlife may be lost because of
                 Generally, wildlife conservation had     land and water resources needed to
                 not been@considered equally with         increase the size of existing Federal
                 other features of the 28 water re-       hydroelectric projects.
                 source developments and the need for
                 equal consideration was demonstrated     Effects of water resource develop-
                 in each of the river basins covered      ments on wildlife can be equally
                 by GAO's review. For example:            considered through effective imple-
                                                          mentation of the coordination proc-
                 --Developments, such as river            ess mandated by the act. (See
                   channelization, flood control          pp. 10 and 12.)
                   levees, diversion outlets, access
                   canals to oil and gas exploration      GAO's review showed significant and
                   sites, and pipelines from produc-      numerous breakdowns in the coordina-
                   tion sites to refineries in            tion process.. To have an effective
                   Louisiana's Atchafalaya River          coordination process, procedures
                   Basin, which contains one.of the       should be established to eliminate
                   largest swamps in North America,       such breakdowns as
                   have resulted in losses of areas
                   for wildlife use.                      --development agencies did not al-
                                                             ways consult with wildlife agen-
                 The basin is rich in sport and com-         cies (see pp. 16, 23, and 24),
                 mercial fish, shellfish, furbearers,
                 waterfowl,.and the nutrients essen-      --wildlife agencies did not ade-
                 tial in the food chain and for de-          quately evaluate wildlife effects
                 pendent marine life in the Gulf of          of proposed developments (see
                 Mexico. Large oil and gas deposits          pp. 16 to 23),
                 are present under a significant por-
                 tion of the Basin, and future de-        --wildlife agencies' study reports
                 velopments can be expected.-                were not furnished to development
                                                             agencies before projects were ap-
                 The bayou shown in the photograph on        proved or authorized, and recom-
                 page 9 illustrates one of many areas        mendations for wildlife conserva-
                 to be lost for wildlife use because         tion in such reports were too gen-
                 of planned developments.                    eral (see pp. 24 to 29),

                                                          2

                 --wildlife agencies did not always          resolve agency differences that af-
                   recommend wildlife mitigation             fect decisions on the levels of    '
                   measures on SCS watershed projects        wildlife conservation.expenditures
                   (see pp. 33 and 34), and                  needed and on whether wildlife en-
                                                             hancement should be included as a
                 --wildlife agencies did not follow          project purpose. (See,pp. 29 to 34).
                   up to determine whether wildlife
                   conservation measures were beinq          Funding and staffing of wiLdlife
                   implemented (see pp. 36 to 39).           agencies

                 Procedures that should be estab-            Wildlife officials frequently cited
                 lished to improve the coordination          inadequate funding and staffing as
                .process are discussed on pages 43           reasons for breakdowns in the co-or-
                 and 44. So that the needs of both           dination process. (See pp. 21 to 23.)
                 wildlife and development agencies           Funding and staffingi therefore, are
                 can be fully understood and ade-            matters which the Secretaries of Com-
                 quately considered, coordinating            merce and the Interior should con-
                 agencies should jointly establish           sider for improving implementation
                 the procedures .                            of the act.

                 Need to clarify  wildlife agencies'
                 roZes                                       RECOMENDATIONS

                 Adequate implementation of the co-
                 ordination process requires close           The Secretaries of the Army, Com-
                 working relationships not only be-          merce, and the Interior should, with
                 tween wildlife and development agen-        the advice of State wildlife agen-
                 cies but also among wildlife agencies       cies, establish
                 themselves. The act recognizes this,
                 but, when it was passed, the latter         --procedures to be observed by their
                 group included one Federal agency, the        agencies in implementing a coordi-
                 Interior's Fish and Wildlife Service,         nation process for carrying out
                 and State wildlife agencies. In 1970,         the requirements of the act and
                 functions of the Service were divided
                 and reorganized so that now they are        --criteria for determining the justi-
                 vested in two agencies in different           fication of the mitigation or en-
                 departments--BSF&W in Interior and            hancement measures for water re-
                 NMFS in Commerce.                             source developments.

                 These two agencies' roles under the         The Secretaries of Commerce and the
                 act have not been clearly defined.          Interior should
                 Agreement on their coordination
                 roles and responsibilities is neces-        --seek an agreement on their wild-
                @sary to avoid duplications and over-          life agencies' respective roles
                 lapping responsibilities, and to ef-          and responsibilities for the coor-
                 fectively use their limited resources.        dinated review of Federal water re-
                 (See pp. 39 to 42.)                           source projects and permits and

                 The establishment of criteria to            --initiate efforts to obtain the
                 better determine mitigation or en-            funds and personnel needed to ef-
                 hancement measures should help                fectively implement the act.

                                                             3

                Because of OMB's role in promoting        AGENCY comeNTs
                efficient, economical, and effec-
                tive Government operations, the           At the Subcommittee's request, GAO
                Director, OMB, should actively par-       did not obtain the written comments
                ticipate with the wildlife and de--       of the Federal agencies on the con-
                velopment agencies in reaching            tents of this report. GAO discussed
                agreement on                              the matters in the report with agency
                                                          officials and considered their views
                                                          in preparing this report.

                --coordination roles and responsi-        MATTERS FOR CONSIDERATION  BY THE
                  bilities,                               SUBCOMMITTEE

                --procedures for implementing the         Pending legislation, House
                  act, and                                bill 10651, wo.uld amend the Fish
                                                          and Wildlife Coordination Act in
                --criteria to be used in determining      several aspects. GAO has     identified
                  the wildlife mitigation and en-         the matters discussed in this report
                  hancement measures. (See pp. 45         which relate to the bill. (See
                  and 46.)                                pp. 47 and 48.)

                                                          4

                                           CHAPTER 1

                                         INTRODUCTION

                       The Fish and Wildlife Coordination Act, as amended
                  (16 U.S.C. 661-666(c-))., provides that wildlife conservation re-
                  ceive equal consideration and be coordinated with other fea-
                  tures of federally licensed or funded water resource develop-
                  ments.

                       The Chairman of the Subcommittee on Fisheries and Wildlife
                  Conservation and the Environment, House Committee on Merchant
                  Marine and Fisheries., asked us to review implementation of
                  sections 2 and 3 of the act. (See app. I.)

                       Section 2 generally provides that (1) Federal develop-
                  ment and permitting' agencies consult with Federal and State
                  wildlife agencies at the earliest stages of planning for or
                  involvement in water resource developments, (2) wildlife
                  agencies study the effects of proposed developments and make
                  recommendations for protecting and improving wildlife re-
                  sources.. and (3) in the case of federally funded projects,
                  development agencies include in any report to the Congress at
                  the time of project authorization those measures they believe
                  are justified for wildlife conservation. Section 3 generally
                  provides that adequate provisions-,, including acquisition of
                  lands and waters, be made at water resource developments for
                  wildlife conservation.

                  THE FISH AND WILDLIFE COORDINATION ACT

                       Legislative recognition that wildlife should be con-
                  sidered in water resource developments licensed or funded by
                  the Federal Government began with passage of the Fish and
                  Wildlife Coordination Act in 1934. The act was amended in
                  19461, 1958, and 1965.

                  'Permits are required to be obtained from various Federal
                   agencies by any parties proposing to control, alter, or dis-
                   charge into navigable waters.

                                               5

                  One Secretary of the Interior hailed the 1958 amendment
             as the most important conservation legislation in a quarter
             century. In effect, it (1) redefined wildlife conservation
             to include development and improvement in addition to the pre-
             vention of loss or damage to wildlife, (2) generally broadened
             the range of water development activities to which the act
             applied, (3) established procedures for reporting on develop-
             ments, and (4) provided that development agencies uniformly
             consider conservation recommendations.

                  Also, the 1958 amendments added section 12 to the Water-
             shed Protection and Flood Prevention Act (16 U.S.C. 1001-
             1009). This section established separate and different coor-
             dination requirements for SCS small watershed projects.,

                  Section 12 requires the Secretary of Agriculture to
             notify the Secretary of the Interior when he authorizes plan-
             ning assistance to local organizations on small watershed
             projects but does not require wildlife studies or consultation
             between the two departments. It provides that the cost of
             making wildlife studies on such projects be borne by the
             Secretary of the Interior from funds appropriated to his De-
             partment. In contrast, the Fish and Wildlife Coordination
             Act requires that consultation between the wildlife and de-
             velopment agencies take place and.that wildlife studies be
             prepared and authorizes the Federal development agencies to
             transfer funds to the wildlife agencies for the cost of such
             studies.

                  Neither the Coordination Act nor section 12 requires that
             conservation measures recommended by the wildlife agencies
             be adopted by the development agencies. Both are permissive
             in this respect.

                  In reviewing implementation of the act, we examined de-
             partmental and agency procedures and guidelines, records, and
             reports; interviewed Federal and State officials; and con-
             sidered related legislation. The agencies covered by our re-
             view were the:

                  --Corps of Engineers (Civil Functions), Department of
                    the Army.

                                           6

                     --Bureau of Reclamation and the Bureau of Sport
                       Fisheries and Wildlife (BSF&W), Department of the
                       Interior.

                     --Federal PowerCommission.

                     --Soil Conservation Service  (SCS), Department of Agri-
                       culture.

                     --National Marine Fisheries Service (NMFS), National
                       Oceanic and.Atmospheric Administration, Department
                       of Commerce.

                     In addition., we visited State wildlife agencies in
                Oregon, Washington, Idaho, Louisiana, and North Carolina.

                     The agencies and programs we selected forreview and
                the locations we visited are listed in appendix II.

                     For our review, we selected water resource developments
                typical of those which have had a major impact on wildlife in
                three geographic areas: The Atchafalaya River Basin in
                Louisiana, the Cape Fear and adjoining Neuse River Basins in
                North Carolina, and the Columbia River Basin in the Pacific
                Northwest. (See app. III for a listing of the 28 water re-
                source developments (17 permits under section 10, and 11 proj-
                ects) which our review covered..)

                                              7

                                          CHAPTER 2

                     NEED TO IMPROVE FEDERAL EFFORTS TO EQUALLY CONSIDER

                        WILDLIFE CONSERVATION WITH OTHER FEATURES OF

                                 WATER RESOURCE DEVELOPMENTS

                      Water resource development and wildlife agencies need
                 to improve their efforts to give wildlife conservation
                 equal consideration with other features of water resource
                 developments.

                      Generally, wildlife conservation had not been considered
                 equally with other features of the 28 water resource develop-
                 ments we reviewed ' and the need for equal.consideration was
                 demonstrated in each of the three river basins covered in
                 our review.

                      --Developments, such as river channelization, flood
                        control levees, diversion outlets, access canals to
                        oil and gas exploration sites, and pipelines from
                        production sites to refineries in the Louisiana's
                        Atchafalaya River Basin., which contains one of the
                        largest swamps in North America (the lower part of
                        which is shown on the map on p. 18), have resulted
                        in losses of areas for wildlife use. The basin is
                        rich in sport and commercial fish, shellfish, fur-
                        bearers, waterfowl, and nutrients essential in the
                        food chain and for dependent marine life in the
                        Gulf of Mexico. Large oil and gas deposits are pres-
                        ent under a significant portion of the Basin, and
                        future developments can be expected. The bayou
                        shown in the photograph on page 9 illustrates one
                        of many areas to be lost for wildlife use because
                        of planned developments.

                      --North Carolina's Cape Fear and adjoining Neuse River
                        Basins have supported about 100 species of fish and
                        game but dams and channelization projects have re-
                        portedly caused some major wildlife losses. For in-
                        stance, anadromous fish have essentially lost access
                        to about 76 miles of spawning and nursery grounds on
                        the Cape Fear River or its tributaries because five
                        navigational dams act as barriers which the fish can
                        only pass during boat lockages or when high water

                                                8

                                                              7

                                                       A

                                                                                          A

                                                           A bayou in  the Atchafalaya River Basin where dredge  material will be dePosited.

                     allows them to swim over the dams. Game fish in
                     North Carolina have reportedly suffered estimated
                     losses of 90 percent following channelization of
                     portions of watersheds in areas like the Neuse
                     River Basin. Throughout North Carolina, 57 water-
                     shed projects involving 3,165,289 acres have been
                     authorized for planning.

                   --The Pacific Northwest's  Columbia River Basin (see
                     map on p. 11), rich in wildlife, has had its water
                     resources developed.extensively for power, naviga-
                     tion, flood control, irrigation, and other purposes.
                     About 62 percent of the Columbia River tributaries are
                     inaccessible to salmon and steelhead trout because
                     of dams, and about 870,000 acres, much of which was
                     big game habitat, has been inundated by reservoirs.
                     More wildlife losses may occur because of lands and
                     water resources needed to increase the size of
                     existing Federal hydroelectric projects.

                   In addition to the direct effects described in the
              above examples, water resource developments can also in-
              directly affect wildlife by inducing changes in agricul-
              tural practices or growth in industrial or commercial
              activities. For example, the billboard shown in the
              photograph on page 13 advertises industrial sites along a
              ship channel to be created by the Corps' Atchafalaya proj-
              ect.' One of the habitat areas in which an industrial
              site will be developed, after it is covered by dredged
              material, is the bayou shown in the picture on page 9.

                   Effects of water resource developments on wildlife can
              be equally considered with other project features through
              the coordination process mandated by the act. The topical
              arrangement of this report generally follows that process
              and points out the breakdowns that have occurred in imple-
              menting each step of it. Essentially, in our opinion, the
              process for federally funded projects should involve the
              following actions.

             .'The Atchafalaya River, Bayous Chene, Boeuf and Black proj-
               ectin Louisiana.

                                          10

                                                                    COLUMBIA RIVER BASIN

                                                                                                                      LEGEND
                                            SCALE IN MILES                                               -ROM PROJECT EXISTING OR UNDER CONSTRUCTION
                                    215 .... 021 50 7-1 100 125 150                                           AUTHORIZED OR LICENSED PROJECT
                                                                                                              RECOMMENDED PROJECT
                                                                                                              PROJECT UNDER STUDY
                                                                                                              NATURAL LAKE WITH STORAGE CONTROL
                                                                                                            S ARMY
                                                                             16                             8 BUREAU
                                                                                                            e: NON-FEDERAL

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                                                               A

                                           N

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                                                                              5S ,E
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                                                                             n
                                                                                   N                                      DWORSHAK DAM
                                                                                               I--     @(                 AND RESERVOIR
                                                                                le,            141                 NOIT. I-FIC D-S,o.

                                                                                                 Al

                                                                                                                             J
                                                    .. ... ......

                                                                          t
                                                                                               ID

                                                    GATE CREEK DAM
                                                     AND RESERVOIR
                                                                                       oi
                                                                                                            . ............. .

                                                                                                             D.
                                                                                                                   LOWER TETON DAM
                                                                                                                     AND RESERVOIR
                                                                                                                                  ... ......

                  --Development agencies, at the-outset of planning a
                    project,.consult wildlife qgencies,, which study the
                    potential wildlife effects. .

                  --After studying the effects, wildlife agencies for-
                    mulate specific wildlife conservation measures and
                    issue a report of findings and recommendations.
                    (The report is to be made an integral part of any de-
                    velopment report going to the Congress in support
                    of authorization.)

                  --On the basis of the wildlife report, development
                    agencies determine the wildlife mitigation and en-
                   .hancement measures that, in their view, are justi-
                    fied and acceptable for inclusion in the project
                    plan.

                  --Following authorization, wildlife. agencies prepare
                    additional detailed reports to solve special prob-
                    lems and assist development agencies in preparing
                    the final project design and specifications.

                  --Development and wildlife agencies jointly prepare
                    and sign a general plan for designating project lands,
                    water, or other project features to be devoted to wild-
                    life conservation.

                  --During project construction and operation, wildlife
                    agencies follow up to insure that conservation meas-
                    ures implemented are adequate and effective in ac-
                    complishing the objectives stated.

                  Although the act's consultation, study, and reporting
             requirements as discussed above are essentially the same
             for section 10 permits and Federal projects, there are sub-
             stantial and significant differences in these two activi-
             ties. Permit applications are processed over a short time--
             usually 30 days--while Federal projects, which are much
             more complex, may be planned over a period of years. Permit
             projects are accomplished predominantly by the private
             sector rather than public agencies. Permit projects are
             usually of smaller individual mag nitude but combined may
             have significant impacts. (See the photograph on page 14
             for an illustration of a permitted activity.) The number
             of section 10 permit applications is estimated to be at
             an annual rate of about 17.,000.in fiscal year 1974.

                                             12

                                                                                                                                                                     %

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                                                                          Billboard along U.S. Highway 90 in Louisiana advertising industrial sites
                                                                          along the ship channel to be created by the Atchafalaya Project.

                                                                                                                                     4*4W

                                                                             A permit was issued to build the breakwater between these
                                                                             oil storage tanks and the waste oil collection Pit.

                  There are hundreds of Federal projects on which project
                  planning isactive.

                       Also., adequately implementing the coordination process
                  described above requires close working relationships not
                  only between wildlife and development agencies but also
                  among wildlife agencies themselves. The act recognizes
                  this, but when it was passed the latter group included one
                  Federal agency, the U.S. Fish and Wildlife Service in the
                  Department of the Interior and State wildlife agencies.

                       In 1970 functions of the Fish and Wildlife Service were
                  divided and reorganized so that now they are vested in two
                  auencies in different departments--BSF&W in the Department
                  of the Interior and NMFS in the Department of Commerce.
                  These two agencies' roles under the act have not been
                  clearly defined and the need for agreement on their co-
                  ordination roles and responsibilities is discussed on
                  pages 39 to 42 of this report.

                  NEED FOR MORE COMPLETE CONSULTATION.
                  AND STUDIES ON WILDLIFE EFFECTS

                       As a first step in the coordination process, the act
                  requires that development agencies consult wildlife agencies
                  concerning conservation of wildlife resources when planning
                  developments and their modifications. Wildlife agencies
                  are required to prepare detailed studies which include (1)
                  the wildlife losses that cannot be avoided by the develop-
                  ment or subsequent modifications, (2) the measures proposed
                  for mitigating or compensating for wildlife damages, and
                  (3) wildlife situations that could be en 'hanced as part of
                  the development, either incidental to. other features or as
                  separate project features.

                       Those consultation and study requirements were not ade-
                  quately implemented in three respects.

                       --For section 10 permits, development agencies did not
                         always consult wildlife agencies.

                       --Although development agencies consulted wildlife
                         agencies on the.federally funded projects and cer-
                         tain permits, the wildlife agencies did not adequately
                         study the expected losses, damages, or opportunities
                         for enhancement.

                                                 is

                   --Development agencies sometimes significantly modified
                     their projects without consulting the wildlife agen-
                     cies.

              Lack of consultation and adequate
              study on section 10 permits

                   Of the 17 permits we reviewed., 10 were not submitted
              to BSF4W for study mainly because of a Corps and BSF&W juris-
              dictional disagreement. The Corps' position was that co-
              ordination was not required for activities permitted in
              geographic areas between mean high tide and mean low tide;
              BSF&WIs was that coordination was required. The Corps has now
              accepted BSF&WIs position.

                   For the remaining seven permits that the Corps sub-
              mitted to BSF&W for consultationt wildlife studies were
              lacking. BSF&W did only a cursory office study on the
              seven permits received. Their reports on these permits
              did not (1) quantify wildlife and habitat losses and dam-
              ages, (2) recommend specific measures to minimize these
              losses and damages, or (3) identify opportunities to im-
              prove wildlife.

                   Because very small acreages usually are involved, less
              detail may be required to evaluate the wildlife effects of
              each permit. For example, the 17 permits covered 26.35
              acres in the Atchafalaya Basin compared to 8,100 acres
              covered by the Atchafalaya project. However, when large
              numbers of permits are in the same general area, wildlife
              agencies also need to evaluate the cumulative wildlife
              effects of development under each permit.

              Wildlife aspects of federally funded projects
              not adequately studied

                   Wildlife agencies did not complete adequate wildlife
              studies for 6 of the 11 proposed projects.we reviewed. No
              more than a preliminary or reconnaissance wildlife study was
              done on any of these six projects. According to BSF&W
              procedures, preliminary studies are only intended to gain
              general familiarity with an area. They are useful for dis-
              cussions with State wildlife agencies and for estimating a
              project's anticipated effects on wildlife.

                                         16

                         The. limited extent of a preliminary study is
                    illustrated by the following two examples taken from
                    the six projects.

                         --Atchafalaya project--BSF&W made a preliminary study
                           of this approved Corps project,-which involves a
                           53-mile-long navigation channel (see map on p. 18)
                           to be constructed for economically moving oil and
                           gas rigs through the Atchafalaya coastal wetlands
                           to various offshore exploration sites. (See photo-
                           graph of a rig on p. 19.) BSF&Wls preliminary study
                           did not identify any wildlife to be lost, damaged
                           or benefited by the project. However, BSF&W of-
                           ficials visited the site at our request during the
                           review and advised us that the project would ex-
                           tensively damage a variety of wildlife resources in
                           and around the proposed channel site.

                         --Teton project--This approved Bureau of Reclamation
                           project involves construction of a 300-foot-high
                           earth-filled dam to supplement the irrigation of
                           about 111,000 acres, generation of about 20,000
                           kilowatts of power, flood control, and recreation.
                           Its location on the Teton River in southeastern
                           Idaho.(see photographs on p. 20) has been of great
                           concern to wildlife interests which-have initiated
                           court action to stop construction on the basis that
                           the project will destroy 17 miles of one of Idaho!s
                           "finest self-sustaining" trout streams and inundate
                           "critical" big game winter range. BSF&WIs prelim-
                           inary study did not show (1) the number of big
                           game animals from adjacent areas using the Teton
                           Basin as winter habitat, (2) the significance of
                           the Teton Basin as a self-sustaining cutthroat
                           trout fishery, and (3) the recreation potential of
                           the.Teton River as a wild and scenic waterway.

                         The other four projects not adequately studied were
                    SCSI Flea Hill, Lyon Swamp-White Oak, Swift Creek., and
                    Upper Bay Watershed projects.

                         Explanations as to why each project and permit was not
                    studied in detail were not always a matter of record. From
                    discussions with agency officials and examination of records
                    that were available for some developments, we noted the
                    following.

                                                17

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                                  PROPOSED ATCHAFALAYA NAVIGATION CHANNEL
                                     OPOSED LOCATIONS WHERE DREDGED MATERIAL WILL BE DEPOSITED

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                                                                                      Drilling rig fabricators construct their rigs in piecemeal fashion, then transport the
                                                                                      pieces to a deepwater port where assembly is completed. Construction of the channel
                                                                                      at the authorized width and depth will allow the rigs to be assembled at one location
                                                                                                                                                              Photograph courtesy of jesse Grice, Photo-Mart

                                                          %

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                                                  A portion of the wildlife habitat and cutthroat trout fishery
                                                  to be eliminated by construction  of the Teton project.

                                                             7",

                                                 This photograph, taken  in August 1972  at the same location as
                                                 shown in the picture above, shows the  wildlife habitat after site
                                                 preparation for the Teton project.
                                                                                                    BSF&W photographs

                                                                           20

                        Wildlife effects believed
                        to be insignificant

                        This reason for the lack of adequate wildlife studies
                   was applied mainly to some watershed projects and permits.
                   For example, lack of probable significant wildlife effects
                   was the reason why only a preliminary study was done on the
                   Corps' Atchafalaya project and SCSI Flea Hill and Upper
                   Bay River watershed projects in North Carolina. The Corps
                   also gave it as a reason for not sending certain.permits to
                   wildlife agencies for study.

                        The act does not use significance as a criterion for
                   determining if studies are needed. But BSF&W procedures
                   allow preliminary studies to be construed as fulfilling the
                   act's study requirements "if it is obvious that the pro-
                   posed project will result in no significant effect on fish
                   and wildlife."

                        Actuallyj information now available indicates that
                   some projects not adequately studied may, in fact, signif-
                   icantly affect wildlife. That evidence is mainly from
                   comments of wildlife agencies on environmental impact
                   statements prepared under the National Environmental Policy
                   Act of 1969 (42 U.S.C. 4321 et seg.) and the results of
                   SCSI and BSF&WIs "108 reviews" to evaluate the degree of
                   environmental damages expected from SCS watershed projects.
                   For example, NMFS, in commenting on the environmental impact
                   statement for the Atchafalaya project, said the project
                   would have a substantial adverse effect on sport and commer-
                   cial fisheries because of the decline in organic food ma-
                   terial produced in the estuary.

                        Lack of funds and staff

                        Wildlife agency officials frequently cited this reason
                   for lack of adequate wildlife studies. For instance, lack
                   of funds and staff was given as the reason why wildlife
                   agencies had been unable to develop baseline environmental
                   data needed to evaluate permits in the Atchafalaya Basin.
                   This reason was also given as to why adequate wildlife
                   studies were not completed on the Teton project.

                        The Corps of Engineers and the Bureau of Reclamation,
                   in accordance with the Coordination Act, transfer funds
                   to BSF&W for wildlife studies of Federal projects. BSF&W

                                               21

             uses direct appropriations to study permits, small watershed
             projects, and other Federal activities.

                  During our review, we tried to determine BSF&Wls
             funding and manpower assigned to the various phases of Co-
             ordination Act work. For selected projects in region 11
             we tried to obtain data on funds needed, requested, re-
             ceived, and actually spent by BSF&W. However, we were un-
             ,able to readily make the determinations because BSF&W
             accounts were not maintained by specific activities and
             projects or in a manner to permit such determinations. For
             example, generally, major activity accounts were maintained
             ,as a single pool of funds covering both Corps and Bureau
             of Reclamation projects and thereafter the use of the funds
             was not readily identifiable for individual projects.

                  After we completed our fieldwork, BSF&W adopted a re-
             vised accounting system, effective July 1, 1973, to provide
             more specific information.

                  In the case of the section 10 permit applications in
             the Atchafalava Basin, information concerning the quality
             and depth of wildlife agency studies suggested to us that
             funding and staffing problems existed. For example, of-
             ficials of the BSF&W Lafayette, Louisiana, field office
             informed us that they had only two staff members to review
             over 100 permit applications received each month in the
             Atchafalaya Basin. From August 1972 to April 1973, only
             20 permit applications received site visits for assessing
             their impact on wildlife and determining possible wildlife
             conservation measures.

                  In most cases, wildlife studies of section.10 permits
             primarily involved an evaluation of information the applicant
             provided. BSF&W officials said that, because their studies
             were limited, they frequently resulted in general comments
             rather than-specific recommendations for wildlife conserva-
             tion. Also these officials said additional funds and staff
             would allow wildlife agencies to gather data to assess the
             cumulative impact of permits.

             'Region I includes Oregon, Washington, Idaho, Hawaii, and
              California.

                                       22

                              NMFS officials informed us that as of June 1973 only
                         one biologist was available to review permit applications
                         in Texas and Louisiana. These officials said that in the
                         Atchafalaya Basin, because of a lack of funds and staff,
                         only a few section 10 permit applications had received
                         site visits. In no case, however, had they performed a
                         detailed wildlife study on a section 10 permit application.

                              Subsequently, BSF&W and NMFS Washington office person-
                         nel made a detailed analysis of their records and files and
                         provided us with agencywide information on their workload,
                         funding, and personnel needs. This information is attached
                         as appendix IV. The information shows an increasing work-
                         load and contains views on theladditional funds and staff
                         the agency officials believe are needed.

                         Wildlife agencies not always consulted
                         on modifications

                              Development agencies should consult with wildlife
                         agencies when projects are modified because such modifica-
                         tions could have a significant impact on wildlife. Some
                         of the projects we reviewed were modified significantly
                         after authorization, but wildlife agencies were not con-
                         sulted. For example:

                              --After authorization of the Teton project, the Bureau
                                of Reclamation reduced the minimum reservoir pool
                                level by 26,500 acre-feet, or 23 percent. We brought
                                this modification to the attention Of BSF&W officials,
                                and they expressed considerable concern over not
                                having the opportunity to study the reduction. These
                                officials pointed out that in their preliminary study
                                of 1961 they had cautioned the Bureau of Reclamation
                                on the need for a storage pool large enough to pre-
                                serve the reservoir's fish population. Reclamation
                                officials could not explain why BSF&W was not con-
                                sulted.

                              --On the Atchafalaya project, the Corps increased the
                                area in which dredge spoils were to be placed by
                                800 acres, or about 10 percent. The Corps did not
                                notify BSF&W of the increase because it believed the
                                change would not have a significant effect on wild-
                                life. When we brought it to the attention of BSF&W

                                                     23

         officials, they regarded the change as significant and
         maintained that it was BSF&WIs responsibility, not the
         Corps', to determine the significance of such changes on
         wildlife.

              According to the BSF&W's Chief of the River Basin Stud-
         ies Division, there were really no formal mechanisms to re-
         port postauthorization changes to BSF&W. For instance, his
         agency might be advised of modifications by letter and
         might meet with the construction agency to discuss them.
         Occasionally, he said, his agency had found modifications
         too late to effectively enter the planning picture, The
         quality and frequency of communication, in his opinion,
         vary considerably among BSF&WIs local officials and de-
         velopment agencies. Bureau of Reclamation officials in-
         formed us also of the lack of formal procedures for
         reporting postauthorization changes to the wildlife  agencies.

         RECO1,24ENDATIONS ON WILDLIFE STUDIES
         SHOULD BE TIMELY AND MORE SPECIFIC

              After a wildlife agency studies the effects of a de-
         velopment, it must furnish a report to the development
         agency containing specific recommendations for wildlife
         conservation. The report should be furnished before devel-
         opment proposals are approved or authorized by the Congress
         or others who approve water resource projects. None of the
         reports furnished for the water resource developments we re-
         viewed met both of these requirements. The recommendations
         were either too general or the reports too late to be con-
         sidered for initial planning or decisionmaking before proj-
         ect authorization. They were available, however, for post-
         authorization planning.

              Although additional studies are needed after project
         approval, it is important that detailed wildlife reports
         be-available before approval of water resource projects.
         The detailed reports would be useful:

               --For project planning. A development agency should
                consider wildlife conservation  at the same time that
                 it.is planning a development's other purposes.

               --For project decisionmaking. To decide on the merits
                 of approving developments or selecting among

                                     24

                            alternativesl information is needed on the wildlife
                            effects, wildlife agency recommendations, and the
                            development agencies' plan for implementing those
                            recommendations.

                          The act recognizes these two purposes and requires
                    that wildlife reports be an integral part of the develop-
                    ment agency reports to the Congress or others who approve
                    water resource projects.

                    Recommendations were not specific

                          The act calls for recommendations to be "as specific
                    as is practicable" concerning features recommended for
                    wildlife conservation and development, lands to be used or
                    acquired for such purposes, and the results expected.

                          BSF&W instructions provide for developing specific
                    recommendations through detailed wildlife reports. Such
                    reports were completed on 5 of the .11 projects, but even
                    in those cases the results were either. not available until
                    after project approval or, like preliminary studies, the
                    reports contained only general recommendations.

                          Following are some examples of wildlife agencies'
                    recommendations on the projects we reviewed.

                          --"Nearby replacement lands should be acquired and de-
                            veloped to provide improved habitat to mitigate this
                            loss [big game animals]." This recommendation on the
                            Teton project did not specify the land to be acquired,
                            the number of acres needed., how it was to be devel-
                            oped, the kind of replacement habitat desired, and
                            when the acquisition should take place in relation to
                            the acquisition of lands for other project purposes.

                          --"Place spoil on existing spoil [dredged material]
                            banks or on other high ground." This recommendation
                            on the Atchafalaya project did not specify the loca-
                            tion of the disposal sites nor the amount of dredged
                            material that could be deposited, even though some
                            sites like that pictured on page 9 appeared to have
                            value as wildlife habitat.

                                                25

              Detailed reports not available for
              project approval

                   Of the five detailed wildlife reports that were
              prepared, long delays were involved in furnishing three
              of them to the development agencies and other circumstances
              were involved in the untimely availability of the remaining
              two.

                   The delays in furnishing the three reports are-shown
              in the following table.

                                                    Detailed Years
                                 Congressional       report      of
                      Project       approval       furnished   delay

                    Gate Creek          1962          1970     8 years
                    Randleman           1968          1973     5 years
                    New Hope            1963          1968     5 years

                   On these three project  's, BSF&W's initial reports to
              the development agencies were based on preliminary studies.
              (called reconnaissance reports). These reports did not
              fully identify wildlife los  ,ses and damages, therefore,
              conservation measures, such as mitigation or enchancement,
              could not be considered fully. Also these preliminary
              studies did not clearly indicate when and if detailed re-
              ports would be forthcoming.

                   BSF&W procedures state that, when a preliminary study
              shows that the proposed project will not significantly af-
              fect wildlife, the-reconnaissance report can be construed
             .as fulfilling the reporting requirements of the act and a
              statement to that effect will be contained in the report.
              If a preliminary study indicates the need for a detailed
              study, the reconnaissance report will recommend a detailed
              study and clearly state that it is only of a reconnaissance
              nature and does not constitute the report required under
              the act. None of the reconnaissance reports on the three
              projects listed in the above table contained such language
              and none recommended that detailed wildlife studies be
              available before project approval.

                   BSF&W work priorities apparently prevented some de-
              tailed studies from being completed in time. For example,

                                             26

               BSF&W officials said they considered the Corps   Gate Creek
               project in Oregon to be low in priority because authoriza-
               tion was being sought for more important projects at the
               same time and that BSF&W did not have the staff, funds, or
               time to prepare detailed reports for each of them.

                    For the fourth project, SCSI Little Contentnea Creek
               Watershed project in North Carolina, the Department of the
               Interior requested that BSF&WIs report, which had been fur-
               nished to SCS-1 year earlier, accompany the project work
               plan when it was forwarded to the Congress. However, the
               report did not accompany the work plan because the Department
               of the Interior did not make this request in time.

                    For the Corps' Dworshak project in Idaho (see photo-
               graph on p. 28), the fifth project for which a detailed re-
               port was prepared, the Congress received in 1962, at the
               time of project approval, a wildlife report that was being
               revised. BSF&W issued a detailed report to the Corps in
               June 1960 to justify its opposition to construction of the
               project. After that report was issued, the Corps notified
               BSF&W in September 1960 that (1) the wildlife agency's
               recommendations were based on incorrect engineering data
               supplied by the Corps and (2) the Corps was considering en-
               larging the project. The effect of the incorrect data and
               the subsequent decision to enlarge the project was that
               7 more stream-miles would be inundated and the reservoir
               area would be increased by about 57 percent. The Corps set
               a target date of June 30, 1961, which BSF&W said it could
               not meet fora new wildlife agency report.

                    Claiming a pressing need for more electric power, the,
               Secretary of the Interior agreed in 1-4arch 1962 that the
               Corps could seek project authorization based on the first
               report; the Congress approved the project in October 1962.

                    BSF&WIs second report, completed in August 1962 and
               not used for project approval, superseded the first report
               because it was based on correct engineering data and the
               Corps' decision to enlarge the project. It dropped any
               objections to project construction in favor of a number of
               wildlife mitigation measures.

                                              27

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                                                                                                                                 Corps photograph
                                                                    Dworshak Dam, Reservoir and Fish Hatchery
                                                 Wildlife resources affected include about 15,000 acres of bi game wintering habitat
                                                 and fish spawning grounds with the potential to accommo   ate 20,000 steelhead and
                                                 16,000 Chinook salmon. Project purposes include operation of 400,000 kilowatts of
                                                 power and 2,000,000 acre-feet of water storage for navigation and flood control
                                                 projects. The estimated total cost was $302 million.

                  NEED FOR CRITBRIA TO DETERMINE THE
                  MITIGATION AND ENHANCEMENT MEASURES

                        Another step in the coordination process provides that
                  wildlife agency reports and recommendations be fully con-
                  sidered in deciding the mitigation and enhancement measures
                  for water resource developments. The act provides also that
                  only those measures considered justifiable by the develop-
                  ment agencies are to be included in project plans. Wildlife
                  officials contend., howeverY that, with the procedures devel-
                  opment agencies use to justify projects and project features,
                  it is all but impossible to justify measures needed to miti-
                  gate project-caused losses, particularly where land acquisi-
                  tion is involved.

                  Criteria is needed
                  for determining mitigation measures

                        For the federally funded developments we reviewed, we
                  found several instances where wildlife officials expressed
                  dissatisfaction with the mitigation measures development
                  agencies decided were justified and would be included in
                  project plans. For example, wildlife officials told us that
                  they asked for

                        --replacement land similar to the bottom land inundated
                          by the New Hope project to be managed as a wildlife
                          preserve, but the Corps offered only project multi-
                          purpose lands on rocky hillsides;

                        .--about 9,500 acres of habitat to be acquired for ex-
                          clusive management as big game wintering range at
                          the nvorshak project, but the Corps agreed to acquire
                          only S,000 acres; and

                        --artifical propagation equal to 20,000 steelhead and
                          16,000 chinook spawners for losses caused by the
                          Dworshak Project, but the Corps would provide hatchery
                          facilities for the equivalent of only 12,000 steel-
                          head spawners.

                        Wildlife officials generally attribute their problems
                  with the mitigation measures to development agencies' appli-
                  cation of the economic analysis procedures developed to
                  implement Senate Document 97, May 29, 1962, and titled

                                               29

                         Standards., and Procedures in the Formulation,
              "Policies,
              Evaluation, and Review of Plans for Use and Development of
              Water and Related Land Resources." They expressed dis-
              satisfaction with those procedures because they result in
              evaluating wildlife losses monetarily, on the basis of
              quantities of recreation days lost rather than in terms of
              habitat.

                   Under the procedures developed to implement Senate
              Document 97, wildlife losses and benefits are evaluated on
              the basis of increases or decreases in recreation-use days
              which can be attributed to the project. Such changes are
              multiplied by a monetary figure for the value of hunting and
              fishing-usedays contained in supplement 1 to Senate Docu-
              ment 97, June 4, 1964, and titled "Evaluation Standards for
              Primary outdoor Recreation Benefits."

                   BSF&W has not used, and has objected to the use of,
              these procedures to measure project losses. As their au-
              thority, BSF&W officials cite Senate report 1981 (85th Con-
              gress), which recommended enacting amendments to the Co-
              ordination Act in 1958. In that report the Senate Inter-
              state and Foreign Commerce Committee stated that it under-
              stood that loss prevention measures "would not have to be
              justified under the iisual benefit-cost type of analysis."
              According to BSF&W officials, the intent was to avoid having
              to use a dollar evaluation of prevented losses as justifica-
              tion for mitigation measures.

                   BSF&W officials said that the Corps, in determining
              whether mitigation measures were justified, frequently took
              the number of man-days of hunting that would be recovered
              under a mitigation proposal, multiplied that figure by the
              daily unit value, and concluded that the benefits did not
              justify the cost.

                   BSF&W officials explained that the error in this ap-
              proach was that the onsite-use values represent only part of
              the environmental values affected. *Use of land for hunting
              is typically low per acre, these officials said, and the
              values derived from hunting are frequently too low to justify
              acquiring land; the result is inevitably an unsatisfactory
              level of mitigation. For example, BSF&W representatives
              said land which.will be inundated by the Teton project pro-
              vides the only unaltered winter habitat for up to 90 percent

                                           30

                  of the deer in the Teton Basin. They contend that construc-
                  tion of the project, therefore, will essentially annihilate
                  this herd--eliminating hunting opportunities not only in the
                  project area but also in the entire Teton Basin as well.

                     . It is of primary importance, according to BSF@W offi-
                  cials, to recognize that the value of having a quality en-
                  vironment extends beyond the value presently quantified in
                  dollars and that no dollar evaluation now in use or in sight
                  provides a reliable guide for deciding to destroy or damage
                  any given environment. They maintain that decisions to
                  damage any given habitat must not and cannot be made on the
                  basis of only the value of hunting and fishing use generated
                  by that area.

                       BSF&W officials stated that there are other values that
                  should be considered, such as the potential of habitat to
                  support wildlife and the quality of recreation experience.
                  The officials also stated that the value of wildlife habitat,
                  like many other basic resources, is relative. Its worth
                  depends on its abundance, or scarcity and desirability, e.g.,
                  a mile of Georgia trout water might ordinarily have a greater
                  value than a similar mile in Vermont. These values are con-
                  sidered "intangible values" because they are difficult to
                  measure monetarily.

                       Wildlife officials stated that the failure to consider
                  intangible values, such as habitat potential, has resulted
                  in disappointing mitigation efforts, especially where big
                  game is-concerned. As a result, they believe that insuffi-
                  cient land has been acquired, developed, and administered
                  specifically to mitigate wildlife losses.

                       Development agencies generally recognize that values
                  other than fishing and hunting are important and should be
                  considered. However, they seem to follow the policy de-
                  scribed by the Corps in the fiscal year 1972 public works
                  authorization hearings.

                       "Until such times as an acceptable procedure or
                       methodology for evaluating intangible habitat
                       values has been approved, the Corps mitigation
                       plans will be governed by the acquisition and
                       development of only those lands needed to support
                       the user days lost when mitigating project-induced
                       fish and wildlife losses."

                                               31

                  The Water Resources Planning Act of 1965 (42 U.S.C.
              1962) established the Water Resources Council. The Council
              established "Principles and Standards for Planning Water and
              Related Land Resources." The new "Principles and Standards"
              which became effective October 30, 1973, replace Senate
              Document 97 as the official rules by which future water re-
              source projects must be planned and executed. The new rules
              place greater emphasis on consideration of nonmonetary ef-'
              fects and environmental quality.

              Problems in achieving wildlife enhancement

                  .The act was amended in 1958 to provide that wildlife
              enhancement could be authorized as a purpose of water re-
              source developments. The amended act provided for enhancing
              wildlife resources by authorizing their development and im-
              provement, including the acquisition of lands for wildlife
              purposes. The Federal Water Project Recreation Act of 1965
              (16 U.S.C. 460(i-13)), establishes cost-sharing criteria for
              enhancing wildlife at Federal water resource projects. It
              provides that, if non-Federal public bodies will bear not
              less than 50 percent of the separable costs of enhancement
              features., the Federal Government will provide the remaining
              construction funds. It does not allow Federal sharing in
              operation and maintenance costs.

                  Wildlife resources ' however, have seldom been improved
              or developed at water resource developments. For example,
              of 103 Corps reservoirprojects authorized since 1965, the
              Corps has recommended to the Congress wildlife enhancement
              measures (exclusive of recreation facilities) at only 4 proj-
              ects. Three reasons for this low rate were described to us.

                   --Definitional problems. According to BSF&W and Corps
                     representatives, defining the limits of enhancement
                     at individual Corps projects has been a problem.
                     Enhancement refers to "improvements" and suggests
                     comparisons of wildlife values with and without the
                     project over a projected future. Involved are ques-
                     tions of what constitutes improvement (e.g., reservoir
                     fishing created versus stream fishing destroyed) and
                     determination of when a loss prevention or mitigation
                     measure becomes an enhancement measure. The differ-
                     ences are important, because enhancement involves cost
                     sharing while costs of mitigation measures are as-
                     signed among all project purposes.

                                             32

                         A related problem, according to BSF&W officials, is
                         that BSF&Wls policy prohibits enhancing one wildlife
                         species to compensate for unmitigated project-caused
                         losses to another species of wildlife (i.e., fish for
                         big game). State wildlife agency representatives
                         said they generally agree with this policy.

                       --Cost-sharing problems. Representatives of State wild-
                         life agencies said they often object to being asked
                         to share the costs of enhancement measures for proj-
                         ects where project-caused losses have not been ade-
                         quately mitigated. Another reason, offered Oregon,
                         is that the costs of enhancing anadromous fisheries
                         should be borne by the Federal Government because
                         anadromous fish substantially benefit areas outside
                         the State's boundaries. Oregon estimates that 50 per-
                         cent of the Coho and 80 percent of the Chinook salmon
                         propagated in Oregon are harvested in the ocean by
                         nonresident interests off CaliforniaP Washington, and
                         British Columbia.

                       --Funding problems. The inability of non-Federal
                         interests to provide matching funds was cited by a
                         Corps official as a reason for lack of enhancement
                         measures.

                 MITIGATION ME-ASURES NOT AL19AYS RECONHENDED
                 ON SCS PROJECTS

                       BSFF1W did not always recommend nitigation measures for
                 SCS watershed projects. For example:

                       --BSF&W did not recommend replacing wildlife losses on
                         the Lyon Swamp-White Oah project, even though the
                         project destroyed 1,16S acres of wildlife habitat and
                         reduced the per-acre fish-carrying capacity of the
                         streams involved from 122 pounds to 58 pounds in the
                         lower end and to I pound in the upper end.

                       --BSF&W did not recommend replacing wildlife losses on
                         the Swift Creek Watershed project in North Carolina,
                         even though the project will reportedly destroy 161
                         acres of hardwood swamps, 1,130 acres of upland hard-
                         wood, 16 acres of good quality fishery habitat, and
                         seriously*impair 469 additional acres of hardwood
                         swamps.

                                                33

                  Section 12 of the Watershed Protection and Flood
             Prevention Act, which governs wildlife coordination for SCS
             small watershed projects, provides that improvements recom-
             mended by BSF&W for wildlife purposes shall be included in
             the work plan if they are "technically and economically
             feasible" and if they are "acceptable to" and "agreed to" by
             both the SCS and local sponsors.

                  However., SCS officials told us that decisions on miti-
             gation measures rest with local sponsors which are reluctant
             to pay for the measures; therefore, BSF&W is reluctant to
             develop them.

                  BSF&W officials advised us that, because of its manpower
             and funding situation, it"musi assign priorities on work to.
             be done. Since local sponsors are reluctant to accept,BSF&W
             recommendations, SCS projects have been given a low priority.
             BST&W is not ready to commit a large expenditure (BSF&W must
             finance studies of SCS projects according to section 12)
             when the results are doubtful.

                  Although the Watershed Protection and Flood Prevention
             Act does permit Federal sharing of design and facility con-
             struction costs, it does not in most cases provide for
             Federal sharing in the cost of acquiring lands to mitigate
             project-induced wildlife losses. Both BSF&W and SCS offi-
             cials said it would be easier to induce local sponsors to
             acquire wildlife mitigation land on small watershed projects
             if the Federal Government shared the acquisition cost.

             WILDLIFE CONSERVATION REMRIENDATIONS
             SHOULD BE JOINTLY PLANNED

                  The step in the coordination process which follows deci-
             sions about the disposition of wildlife mitigation and en-
             hancement recommendations is the preparation of plans for
             incorporating accepted measures into the overall project
             development plan.

                  Section 3(b) requires that the use of lands, water,    or
             interests for wildlife conservation shall be in accordance
             with general plans. The plan is to be approved jointly by
             the development agency, the State wildlife agency, and the
             Department of the Interior. The agencies prepare documents
             called general plans, but, rather than containing wildlife

                                            34

                  management plan-s, they are simply agreements outlining lands
                  to be managed for wildlife' and specifying the managing
                  agency. Joint wildlife management plans are generally not
                  prepared for water resource developments except the ones the
                  Federal Power Commission (FPC) licenses.

                       FPC requires joint planning of wildlife conservation
                  measures for utility projects subject to its licensing.
                  Wildlife agencies' officials said FPCIs licensed projects
                  are better coordinated than Federal resource developments
                  because FPCIs licensing procedures

                       --encourage the utilities and wildlife agencies to work
                         out mutually acceptable wildlife mitigation plans
                         through negotiation,

                       --reduce agreements reached on wildlife matters to a
                         wildlife mitigation plan--called exhibit S--which is
                         made a part of the licensing, and

                       --provide a basis for enforcing agreements through
                         public hearings.

                       A key factor in the coordination between utilitie  s and
                  wildlife agencies appears to be exhibit S. FPC ordered the
                  exhibit to be prepared in 1966 to help expedite the process-
                  ing of license applications and to make FPCIs compliance with
                  the act easier.. When the requirement for the exhibit was
                  first announced, FPC solicited comments and received wide
                  approval from interested parties. Of 32 respondees to FPCIs
                  request, 23 expressed unqualified approval, 8 generally sup-
                  ported the concept, and only 1 utility objected to it.

                       Exhibit S provides a way to insure full coordination
                  between utilities and wildlife agencies because it must be
                  prepared on the basis of studies made after consultation and
                  in cooperation with wildlife agencies; also, because it is
                  made part of the license, later misunderstandings about
                  agreements are minimized.

                       We believe that a similar procedure for the joint plan-
                  ning of mitigation and enhancement measures by the develop-
                  ment and wildlife agencies would help enhance the effective-
                  ness of the wildlife management plans.

                                                35

                 FOLLOWUP NECESSARY TO DETERMINE
                 WHETHER ACCEPTED WILDLIFE CONSERVATION
                 MEASURES ARE BEING IMPLEMENTED

                      When water resource project plans are being implemented,
                 a last step in the coordination process should involve fol-
                 lowup by the wildlife agencies to help insure that the devel-
                 opment agencies are adequately providing for the wildlife
                 conservation measures they accepted. Wildlife agencies
                 should, during project design, construction, and operation,
                 determine whether Cl) recommendations have been accepted,
                 (2) accepted recommendations have been implemented, C3) rec-
                 ommendations have proved to be biologically sound and effec-
                 tive, (4) additional measures for wildlife conservation
                 should be incorporated into the development, and CS) lessons
                 learned can benefit future developments.

                      Generally, BSF&W did not follow up on the projects or
                 permits we reviewed. BSF&W representatives, however, while
                 conducting a review of another project, did discover a num-
                 ber of conditions which they considered inadequate in the
                 construction of the Teton project. For instance, an access
                 road was being built along the Teton River below th-e project
                 site rather than along the canyon rim where wildlife offi-
                 cials understood it would be constructed. Th-ese conditions
                 were reported to Bureau of Reclamation officials and some
                 corrective action was taken. CSee photographs on pp. 37 and
                 38 for illustration of the damages caused by this road con-
                 struction.)

                      BSP&W procedures call for, and its officials recognize
                 the value of, determining whether adequate provisions are
                 made for wildlife conservation on both projects and permits.
                 However3 BSF&W officials told us such followups had seldom
                 been made. BSF&W h-ad made only three such follow-ups in its
                 western region--region 1-and four in its southeastern
                 region--region 4--since January 1966. BSF&W officials
                 explained that more follow-ups have not been made because of
                 a lack of staff and funds.

                                              36

                                                        rI

                                                 a
                                              W,
                                             I 'A
                                                                                                          t
                                                 @V I

                                               Native condition of Teton River and adjacent wildlife habitat at
                                               the location of proposed access road construction.

                                                                                                         -*JAI
                                                                                    T.

                                                                           -*E@- W,

                                               Piles of excavated material and other habitat disturbances resulting
                                               from access road construction below the Teton Dam site. Wildlife
                                               officials wanted the road located above the canyon rim to prevent
                                               covering the shoreline habitat, destroying fish spawning gravels, and
                                               causing downstream siltation in the river.

                                                                                                   BSF&W photographs
                                             t

                                                                               37

                                               W71

                                                                                           Ik
                                                                                                        i-   tow

                                           Bulldozer working in the Teton River. BSF&W officials questioned
                                           whether this section of river will ever regain its original quality.

                                                                                                    it

                                           N,I

                                           Excavated material lining banks of relocated Teton River below the
                                           Teton Project site has begun to collapse into the river causing mud
                                           and silt to wash downstream. Note dragline in foreground dredging
                                           original channel. River was relocated to make room for access road.

                                                                                               SSF&W photographs

                                                                           38

                 NEED FOR THE WILDLIFE AGENCIES TO AGREE ON
                 COORDINATION ROLES AND RESPONSIBILITIES

                      Wildlife agencies should coordinate their activities to
                 insure that their full expertise and capabilities are made
                 available to the development agencies.

                      Before 1970, the Fish and Wildlife Service's Bureau of
                 Commercial Fisheries (BCF) and BSF&W carried out their roles
                 in implementing the act by working within their respective
                 functional areas. These functional areas, established by the
                 Fish and Wildlife Act of 1956 (16 U.S.C. 742a) and refined
                 by the Department of the Interior Reorganization Memorandum
                 No. 12 (Oct. 6, 1958) and No. 20 (Sept. 8, 1959), gave BSF&W
                 primary investigating and reporting responsibility, while BCF
                 remained an advisor to BSF&W on matters concerning commercial
                 fisheries. BCF 11ad sole responsibility for investigating
                 fish.ery aspects of developments proposed in the Columbia
                 River Basin, but BSF&W had primary reporting responsibility
                 for fish and wildlife. BCF had field responsibility for
                 investigating and reporting on fish and wildlife aspects of
                 developments in Alaska. Reorganization Plan No. 4 of 1970,
                 however, transferred some of the Service's functions from the
                 Department of the Interior to the Department of Commerce.

                      The wildlife reports for the projects reviewed were pre-
                 pared in accordance with the arrangement in effect before the
                 reorganization plan.

                 Impact of Reorganization Plan No. 4
                 on the Fish and Wildlife Service's functions

                      The reorganization plan, which was designed to consoli-
                 date Federal resources concerned with the problems of the
                 oceans and the atmosphere, transferred BCF1s activities and
                 BSF&Wls Marine Sport Fishery Program to Commerce's newly
                 created National Oceanic and Atmospheric Administration (the
                 parent agency of NMIFS). However, the plan did not address
                 those functions vested in the Fish and Wildlife Service and
                 shared jointly by both BCF and BSF&W under the act.

                      The effect has been to divide into two departments the
                 Federal responsibility for reporting in two areas of fish and
                 wildlife resources. The first area involves anadromous fish
                 which spend part of their life cycle in freshwater and
                 another part in saltwater; the second involves the fishery
                 resources in the coastal or estuarine zone.

                                              39

                   At a March 1972 meeting, the Board agreed that a small
              task force, composed of field office officials from BSF&W and
              VUS, would be established for the Columbia River Basin to
              identify areas of disagreement, delineate the role of each
              department, and recommend procedures to promote and insure
              cooperation. Because of the task force recommendations, the
              regional directors for both agencies in the Northwest entered
              into an agreement for the Columbia River Basin in July 1972.
              The agreement provided, among other things, that BSF&W and
              NMFS proceed to independently conduct investigations and pre-
              pare separate reports. However, the Department of the Inte-
              rior rejected the agreement because it wanted to retain
              responsibility for preparing the wildlife reports.

                   Recently NMFS has initiated certain actions, independent
              of BSF&W, that ultimately will enable it to fully assume its
              investigating and reporting responsibilities. Following are
              some of these actions.

                   1.  NMFS has informed the water resource planning and
                       development agencies of its desire to be notified of
                       all projects, permits, and licenses in the marine,
                       estuarine., and anadromous fish areas.

                   2.  NMFS regional directors have contacted agency
                       counterparts to develop working arrangements ulti-
                       mately leading to memorandums of understanding
                       between the Department of Commerce and tHe develop-
                       ment agencies.

                   3.  Each NMFS regional director has made interim
                       arrangements with his counterpart in BSF&W for the
                       coordinated review of Federal water resources proj-
                       ects and permits until NMFS obtains full staffing
                       and funding. '

                   BSF&W maintains that under the reorganization all
              investigating and reporting responsibilities under the act,
              including those in the anadromous fish and estuarine areas,,
              remain within t1ne Department of the Interior. NMFS argues
              that BCF1s roles and responsibilities under the act were
              transferred to Commerce at the time' of the reorganization
              along with its scientific and technical expertise in the
              marine, estuarine, and anadromous fisheries areas.

                                          40

                 The agreement provided, among other things, that BSF&W and
                 NMFS proceed to independently conduct investigations and pre-
                 pare separate reports. However, the Department of the Inte-
                 rior rejected the agreement because it wanted to retain
                 responsibility for preparing the wildlife reports.

                      Recently NMFS has initiated certain actions, independent
                 of BSF&W, that ultimately will enable it to fully assume its
                 investigating and reporting responsibilities. Following are
                 some of these actions.

                      1.   NMFS has informed the water resource planning and
                           development agencies of its desire to be notified of
                           all projects, permits, and licenses in the marine,
                           estuarine,, and anadromous fish areas.

                      2.   NM.FS regional directors have contacted agency
                           counterparts to develop working arrangements, ulti-
                                          to memorandums of understanding
                           between th-e Department of Commerce and the develop-
                           ment agencies.

                      3.   Each NMFS regional director has made interim
                           .arrangements with his counterpart.in BSF&1V for the
                           coordinated review of Federal water resources pToj-
                           ects and permits -until NMFS obtains full staffing
                           and funding.

                      NMFS has contacted the development agencies and,
                 although agreements have not been made, NMFS officials are
                 optimistic that some type of interim, arrangements will be
                 made.' They have stated, however, as have development agency
                 officials, that any memorandums of understanding will ulti-
                 mately have to include BSF&W as a third party.

                      Implementation of current legislation in the permit
                 area indicates a greatly expanded role for BSF&W and NMFS.
                 Section 402 of the Federal Water Pollution Control Act Amend-
                 ments of 1972 (33 U.S.C. 1151) transferred the Corps'
                 authority to issue permits for discharges into navigable

                 'On Oct. 5, 1973, MFS and the U.S. Forest Service entered
                  into a Memorandum of Understanding.

                                              41

             waters to the Administrator of the Environmental Protection
             Agency (EPA). This transfer resulted in increased emphasis
             being placed on this permit program. EPA officials have
             stated that by December 1974 they will have issued public
             notices on about 61,000 pending and probable applications
             for discharge permits.

                  An agreement worked out in May 1973 between interested
             Federal agencies interprets the Fish and Wildlife Coordina-
             tion Act to apply to the section 402 permits. Both BSF&W and
             NMFS will have an opportunity to review and comment on all
             permit applications. Wildlife agencies have 30 days to
             review and comment to EPA on the permit applications and can
             request time extensions.

                  According to wildlife agency officials, this new program
             responsibility was assumed without a corresponding immediate
             increase in funds and manpower. After the initial backlog of
             applications is processed, these officials expect a workload
             of about 15,900 applications a year.

                  NMFSI recent actions, without benefit of agreement with
             BSF&W concerning respective roles and responsibilities in the
             estuarine and anadromous fish areas, are a potential source
             of confusion to Federal development agencies, State wildlife
             agencies, and permit applicants. This factor, when consid-
             ered along with (1) the wildlife agencies' views on the need
             for additional funds and staff and (2) the backlog of sec-
             tion 402 permit applications requiring review and comment,
             makes resolving the differences between NMFS and BSF&W of
            .utmost importance.

                                            42

                                        CHAPTER 3

                             CONCLUSIONS AND RECOMMENDATIONS

               CONCLUSIONS

                    For the 28 developments reviewed, the act's requirement
               to consider wildlife conservation equally with other de-
               velopment features had not been effectively carried out.
               To achieve equal consideration, more effective implementation
               of the act's coordination process is necessary. To have an
               effective coordination process, procedures should be estab-
               lished and actions taken to require that:

                    --Wildlife agencies should.continually be consulted
                      during, and actively participate in, project.plan-
                      ning and decisionmaking before project authorization
                      and on planned project modifications after author--
                      ization.

                    -Wildlife studies of projects and permits should be
                      detailed enough to evaluate their individual and
                      cumulative wildlife effects; otherwise, ways to pre-
                      vent or replace losses, lessen damages, or enhance
                      wildlife cannot be adequately determined or jus-
                      tified.

                    --Recommendations for wildlife conservation should
                      clearly specify the mitigation and enhancement
                      measures to be taken.

                    --Reports on wildlife studies should be furnished be-
                      fore developments are approved so that wildlife
                      conservation measures can be planned concurrently
                      with other project purposes and so that decision-
                      makers, including the Congress, can base their   ap-
                      proval actions on full knowledge of wildlife
                     ,consequences.

                    --Wildlife and development agencie s should agree on
                      criteria for determining and justifying the miti-
                      gation and enhancement measures necessary to insure
                      that conservation plans are adequate.

                    --Wildlife enhancement possibilities for federally
                      funded projects should be identified and reported

                                            43

                      by wildlife agencies regardless of mitigation
                      disputes, anticipated funding difficulties, or ob-
                      jections by State or local project sponsors, so that
                      the Congress and other approval authorities can con-
                      sider them.

                    --The development agency, together with wildlife      agen-
                      cies, should prepare a general plan for implementing
                      recommended wildlife conservation measures. The plan,
                      which would be included in project authorization docu-
                      ments, would help insure full consideration of the
                      recommendations and their effective implementation
                      during project design, construction, and operation.

                    --Wildlife agencies should follow up after plan approval
                      to determine whether adequate provisions have been
                      made for wildlife during a project's design, construc-
                      tion, and operation.

                    Coordination procedures should also specify how each
               step in the planning, decisionmaking, and action process for
               wildlife conservation is to be integrated with these same
               steps for other development features. So that the needs of
               both wildlife and development agencies can be fully under-
               stood and adequately considered, coordinating agencies
               should jointly establish the procedures.

                    Reorganization Plan No. 4 of 1970 divided the functions
               of the Fish and Wildlife Service so that they are now vested
               in two agencies--BSFW in the Department of the Interior and
               NMFS in the Department of Commerce. However, the Reorgani-
               zation Plan did not clearly define the coordination roles
               and responsibilities of the two agencies and interdepartmental
               efforts to reach agreement on them have been unsuccessful.
               Until the roles and responsibilities are clearly defined and
               agreed upon, we believe that duplication of effort and omis-
               sions of work can occur because some function*s overlap,
               neither agency claims to have had the resources to do all the
               work, and each agency maintains, in certain instances, to
               have primary responsibility for wildlife consultation and re-
               porting on water resource developments.

                    Also, establishing criteria to better determine the
               mitigation or enhancement measures for water resource de-
               velopments should help resolve agency differences that affect

                                             44

                 decisions on the levels of wildlife conservation expenditures
                 needed and whether wildlife enhancement should be included
                 as a project purpose.

                      Wildlife officials frequently cited inadequate funding
                 and staffing as reasons for breakdowns in the coordination
                 process. Funding and staffing, therefore, are matters which
                 we believe the Secretaries of Commerce and the Interibr
                 should consider for improving implementation of-the act.

                      The Office of Management and Budget (OMB) is responsible
                 for insuring that Federal agency programs are effectively
                 coordinated and that funds are spent most economically with
                 the least amount of duplication. OMB should, therefore,
                 assist the wildlife agencies in agreeing on their coordi-
                 nation roles and responsibilities and assist the wildlife
                 and development agencies in establishing criteria for deter-
                 mining mitigation and enhancement measures.

                 RECOMMENDATIONS TO THE SECRETARIES
                 OF THE ARMY, COMMERCE, AND THE INTERIOR

                      We recommend that:

                      --The Secretaries of the Army, Commerce, and the Inte-
                        rior, with the advice of State wildlife agencies,
                        establish (1) procedures to be jointly observed by
                        their agencies in implementing a coordination process
                        for carrying out the requirements of the act and (2)
                        criteria for determining the justification of the
                        mitigation or enhancement measures for water resource
                        developments.

                      --The Secretaries of Commerce and the Interior should
                        (1) seek an agreement on their wildlife agencies'
                        respective roles and responsibilities for the coor-
                        dinated review of Federal water resource projects and
                        permits and (2) initiate efforts to obtain the funds
                        and personnel needed to effectively implement the
                        act's requirements.

                 RECOMMENDATION TO THE DIRECTOR, OMB

                      Because of OMB's role in promoting efficient, economical,
                 and effective Government operations, we recommend that the

                                               45

             Director, OMB, actively participate with the wildlife and
             development agencies in reaching agreement on (1) coordi-
             nation roles and responsibilities, (2) procedures for imple-
             menting the act, and (3) criteria to be used in determining
             the wildlife mitigation and enhancement measures.

                                           46

                                          CHAPTER 4

                              COMMENTS ON PROPOSED LEGISLATION

                      House bill 106S11 introduced in the first session of
                 the 93d Congress, would amend several aspects of the Fish
                 and Wildlife Coordination Act. House bill 10651 would:

                      --Require any development agency proposing a water re-
                        source development to obtain a.written report from
                        the wildlife agencies setting forth their views, com-
                        ments, objections, and recommendations on the develop-
                        ment. Such reports shall specify.the measures and
                        features recommended for wildlife conservation and
                        development, the lands to be used or acquired for such
                        purposes, the results expected, the damage to wildlife
                        attributable to the projects, and the measures pro-
                        posed for mitigating or compensating for such damages.

                        Pages 15 to 27 of this report discussed the need for
                        such reports to be developed. through better consulta-
                        tion between agencies, more detailed studies of wild-
                        life effects, more specific wildlife recommendations,
                        and completion of wildlife reports in time for them
                        to be used for project approval purposes.

                      --Provide that a project not be carried out, financed,
                        or authorized until wildlife agencies have written the
                        development agency that they are satisfied that each
                        recommendation to prevent or mitigate wildlife losses
                        is adequately provided for before or concurrently with,
                        project development, unless the head of the development
                        agency specifies his reasons, in writing, that adopting
                        the recommendations would be contrary to the public
                        interest. The bill also states that, to the greatest
                        extent possible, recommendations for enhancing wildlife
                        resources shall be adopted.

                        Pages 32 to 36 of this report discuss (1) problems in
                        achieving wildlife enhancement, (2) the need for wild-
                        life and development agencies to jointly plan the im-
                        plementation of wildlife conservation recommendations,
                        and (3) the need for wildlife agencies to follow up on
                        their recommendations to determine whether accepted
                        wildlife conservation measures are being implemented.

                                              47

                     --Prohibit any development agency from requiring solely
                       monetary estimates of wildlife losses as justification
                       for adopting wildlife recommendations. Pages 29 to 33
                       of this report discuss the need for wildlife and de-
                       velopment agencies to jointly establish criteria for
                       determining the wildlife mitigation and enhancement
                       measures to be taken.

                     --Specifically provide that development agencies consult
                       with the  National Oceanic and Atmospheric Administra-
                       tion and BSF&W on the wildlife aspects of projects.
                       Pages 39  to 42 of this report discuss the need for
                       Commerce  and the Interior to agree on their respective
                       wildlife  agencies' coordination roles and responsibili-
                       ties.

                     --Repeal section 12 of the Watershed Protection and
                       Flood Prevention Act, which provided separate and dif-
                       ferent coordination requirements for SCS small water-
                       shed projects, and include SCS projects under the Fish
                       and Wildlife Coordination Act.

                       Page 6 of this report discusses the differences in
                       the coordination requirements under the two acts and
                       pages 33 and 34 discuss problems in obtaining mitiga-
                       tion on SCS projects.

                                                                                                       APPENDIX I

                                               NINETY-SECOND CONGRESS                                                                                                           CHIEF COUNSEL
                                                                                                                                                                                 RALPH E. CASEY
                                               EDWARD A. GARMATZ. MD., CHAIRMAN                                                                                                 COUNSEL
                      LEONOR K. (MRS. JOHN B.) SULLIVAN. Mo.      THOMAS M. PELLY, WASH.                                                                                         NED P. EVERETT
                      FRANK M.CLARK,PA.                           WILLIAM S. MAILLIARD CALIF
                      THOMAS L. ASHLEY, OHIO                      CHARLES A. MOSHER,OHIO                                                                                         ERNEST J. CORRADO
                                                                                                                                                                                 ERNEST SUTTER
                      JOHN D. DINGELL, MICH.                      JAMES R. GROVER, JR., N.Y.                                                                                    FRANCIS D. HEYWARD
                      ALTON LENNON, N.C.                          HASTINGS KEITH, MASS.                                     U.S. HOUSE OF REPRESENTATIVES                      A. RONALD SANTO
                      THOMAS   N. DOWNING, VA.                    PHILIP E. RUPPE. MICH.                                    Committee on                                       FRANK M. POTTER, JR.
                      JAMES A. BYRNE, PA.                         GEORGE A. GOODLING, P    .                             Merchant Marine and Fisheries
                      PAUL G. ROGERS, FLA.                        WILLIAM G. BRAY. IND.                                     Room 1334, Longworth House Office Building         MINORITY COUNSEL
                      FRANK  A. STUBBLEFIELD, KY.                 PAUL  N. MCCLOSKEY, JR.,CALIF.                                Washington, D.C. 20515
                      JOHN M. MURPHY, N.Y.                        JACK H. MC DONALD, MICH-                                        March 16, 1972                               RICHARD C. SHAROOD
                      WALTER B. JONES, N.C.                       M. G. (GENE) SNYDER, KY.                                                                                     WILLIAM ROUNTREE
                      ROBERT L. LEGGETT. CALIF,                   ROBERT H. STEELE, CONN.
                      SPEEDY 0. LONG, LA.                         EDWIN 8. FORSYTHE, N.J-
                      MARIO BIAGGI. N.Y.                          PIERRE S. (PETE) DUPONT, DEL.
                      CHARLES H. GRIFFIN, MISS.                   WILLIAM 0. MILLS, MO.
                      GLENN M. ANDERSON. CALIF.
                      ELIGIO DE LA GARZA, TEX.
                      PETER N. KYROS. MAINE
                      ROBERT 0. TIERNAN, R.I.
                      JAMES V. STANTON, OHIO
                      RALPH H. METCALFE, ILL.

                                               ROBERT J. MCELROY, CHIEF CLERK

                                               Honorable Elmer B. Staats
                                               Comptroller General of the United States
                                               General Accounting Office
                                               441 Street, N. W.
                                               Washington, D. C. 20548

                                               Dear Mr. Staats:

                                                            The Fish and Wildlife Coordination Act of 1958, as
                                               amended, states that fish and-wildlife conservation shall
                                               receive equal consideration with other project purposes
                                               and be coordinated with other features of water-resources
                                               development programs. Adverse effects on fish and wild-
                                               life resources and opportunities for their improvement
                                               are to be examined along with other purposes which might be
                                               served by water resource developments.

                                                            Section 2 of the Act provides that prior to under-
                                               taking any water resources project, the responsible agency
                                               shall first consult with the U.S. Fish and Wildlife Service,
                                               Department of the Interior, and with the head of the agency
                                               administering the wildlife resources of the State wherein
                                               the project is to be carried out in order to conserve and
                                               protect wildlife resources as well as to provide for their
                                               development and improvement.

                                                            Section 3 provides whenever a project is to be carried
                                               out by any Federal agency, adequate provision shall be made,
                                               consistent with the primary purposes of the project, for the
                                               use thereof, together with any areas acquired or administered
                                               by such agency in connection therewith, for the conservation,
                                               maintenance and management, and improvement of the wildlife
                                               resources thereof and its habitat thereon. Section 3 also

                                                 THIS STATIONERY PRINTED ON PAPER MADE WITH RECYCLED FIBERS

                                                                          49

                APPENDIX I

               provides that land andwaters may be acquired by Federal
               construction agencies for-wildlife conservation and
               development in connection with a project, provided that
               prior to such acquisition, a report is submitted to
               Congress describing the extent of the acquisition.

                      I would like your office to examine into the
               manner in-which Sections 2 and 3 of the Act are being
               implemented by the Department of the Army, Corps of
               Engineers (Civil Functions), Department of Agriculture,
               the Department of the Interior, and the Department of
               Commerce (NOAA Functions) and to furnish the Subcommittee
               a report on the results of.your review.

                                             Sincerely,

                                             John D. Dingell, Chairman
                                             Subcommittee on Fisheries
                                             and Wildlife Conservation

                                             50

                                                                   APPENDIX II

                         AGENCIES AND PROGRAMS SELECTED FOR REVIEW

                                    AND LOCATIONS VISITED

                DEVELOPMENT AGENCIES:

                     Bureau of Reclamation, Department of the Interior:

                         Construction and Rehabilitation Program:
                            .Office of the Commissioner of Reclamation,- Washing-
                               ton, D.C.
                             Pacific Northwest Region, Boise, Idaho

                     Corps of Engineers, Department of the Army:

                         Civil Works Progr am:
                             Office of the Chief of Engineers, Washington, D.C.
                             North Pacific Division Office, Portland, Oregon
                             Portland District Office, Portland,, Oregon
                             Walla Walla District Office, Walla Walla, Wash-
                               ington
                             New Orleans District Office, New Orleans,
                               Louisiana
                             Wilmington District Office, Wilmington, North
                               Carolina

                     Federal Power Commission:

                         Non-Federal Hydroelectric Power Licensing Program:
                             Headquarters, Federal Power Commission, Washington,
                               D.C.

                     Soil Conservation Service, Department of Agriculture:

                         Watershed projects (Public Law 83-566):
                             Office, Deputy Administrator for Watershed, Washing-
                               ton, D.C.

                             State office:
                                 Soil Conservation Service, Raleigh, North
                                   Carolina

                                               51

              APPENDIX II

              WILDLIFE AGENCIES:

                  Bu reau of Sport Fisheries and Wildlife, Department of
                    the Interior:
                      Headquarters, Washington, D.C.
                      Region 1 office, Portland, Oregon
                      Portland area office, Portland, Oregon
                      Boise area office, Boise, Idaho
                      Region 4 office Atlanta, Georgia
                      Vicksburg area ;ffice, Vicksburg, Mississippi
                      Lafayette area office, Lafayette, Louisiana
                      Raleigh area office, Raleigh, North Carolina

                  National Marine Fisheries Service, Department of Commerce:
                      Headquarters, Washington, D.C.
                      Northwest regional office, Seattle, Washington
                      Columbia Fisheries Program Office, Portland, Oregon
                      Boise area office, Boise, Idaho
                      Southeast regional office, St. Petersburg, Florida
                      Beaufort area office, Beaufort, North Carolina

                  States: .
                      Idaho Fish and Game Department, Boise, Idaho
                      Oregon Fish Commission, Portland, Oregon
                      Oregon Game Commission, Portland, Oregon
                      Washington Fish Department, Olympia, Washington
                      'Louisiana Wildlife and Fisheries Commission, New
                        Orleans, Louisiana
                      North Carolina Wildlife Resources Commission, Raleigh,
                        North Carolina (Game Division and Fish Division)

                                           52

                                                                                                     APPENDIXIII

                                               WATER RESOURCE DEVELOPMENTS SELECTED FOR REVIEW

                                                                           Approval date
                                                   Basin and                and status
                        Development                 location                as of 7-73                     Features

                 Bureau of Reclamation
                   project:
                     Lower Teton Dam and       Columbia River,       1964 (under construction)     Irrigation, power, flood
                       Reservoir                 Idaho                                               control, and recreation

                 Corps of Engineers
                   projects:
                     Dworshak Dam and          Columbia River,       1962 (under construction)     Power, flood control, naviga-
                       Reservoir                 Idaho                                               tion, and recreation
                     Gate Creek Dam and        Columbia River,       1962 (construction            Flood control, irrigation, and
                       Reservoir                 Oregon                not started--low  Corps       navigation
                                                                       priority).
                     Randleman Lake Dam        Cape Fear River,      1968 (design)                 Flood control, water supply,
                       and Reservoir             North Carolina                                      water quality and sedi-
                                                                                                     mentation
                     New Hope Dam Re-          Cape Fear River,      1963 (under construction      Flood control, water supply,
                       servoir                   North Carolina        but portions stopped by       water quality control, and
                                                                       court order)                  recreation
                     Atchafalaya River,        Lower Atchafalaya     1968 (final design)           Navigation
                       Bayous Chene,             River,
                       Beouf and Black           Louisiana
                       (Atchafalaya)

                 SCS projects:
                     Flea Hill Watershed       Cape Fear River,      1966 (completed)              Land treatment, flood con-
                                                 North Carolina                                      trol, and drainage
                     Lyon Swamp-White Oak      Cape Fear River,      1964 (completed)              Flood and erosion protection
                                                 North Carolina
                     Swift Creek Watershed     Neuse River,          1969 (final design)           Flood prevention and drainage
                                                 North Carolina
                     Little Contentnea         Neuse River,          1966 (construction not        Flood control, agricultural
                       Creek Watershed           North Carolina        started because of            water management, and land
                                                                       court order)                  treatment
                     Upper Bay River           Neuse River,          1970 (construction not        Flood control and land
                       Watershed                 North Carolina        started because of            treatment
                                                                       court order)
                     17 Corps of  Engineers    Lower Atchafalaya     Fiscal year 1971 and 1972     14 permits for construction
                       Permits                   River,                (some completed, others       of access to oil and gas
                                                 Louisiana             in process)                   sources, 2 permits for
                                                                                                     construction of bulkheads,
                                                                                                     and 1 permit for construc-
                                                                                                     tion of a wharf

                                                                       53

               APPENDIX IV

                            ESTIMATES OF BSF&W-NMFS WORKLOAD,

                              FUNDING, AND MANPOWER NEEDS FOR

                            FISH AND WILDLIFE COORDINATION ACT

                              AND RELATED ENVIRONMENTAL WORK

                    BSF&WIs and NMFSI Washington headquarters personnel
               developed the information contained in this appendix without
               our verifying it. Agency statements and estimates did not
               receive official departmental review.

               BUREAU OF SPORT FISHERIES AND WILDLIFE

                    The Fish and Wildlife Coordination Act authorizes trans-
               fers of funds to the wildlife agencies from development agen-
               cies to make wildlife studies under the act. Historically,
               funds received from these sources have been used exclusively
               for preauthorization and postauthorization studies of major
               Corps and Bureau of Reclamation projects, a limited number
               of navigation projects, and small flood control works.

                    Such transfer funds, however, have not been available
               for those program areas which have experienced the most rapid
               growth. The program areas include BSF&W involvement in (1)
               Corps section 10 permits, (2) EPA's pollutant discharge per-
               mits, (3) Atomic Energy Commission (AEC) nuclear power in-
               vestigations, (4) SCSI small watershed program, and (5) en-
               vironmental statements prepared under the National Environ-
               mental Policy Act. These rapidly growing program areas have
               been financed from funds appropriated directly to BSF&W.
               Funds derived from this direct source, until recently, could
               not be increased markedly and were relatively static through
               the 1960s. BSF&W, therefore, has been faced with a rapid ex-
               pansion in workload which had to be financed from a fund base
               that did not keep pace with the expanding needs of the pro-
               gram.

                    Also, BSF&W personnel ceiling needs have had to be met
               entirely from the Interior sources. Despite the substantial
               sums of money available from transfer funds, no personnel
               ceilings are transferred with those funds and this lach of
               manpower authorizations has greatly inhibited the requests
               for transfer funds over the years and prevented a desirable
               expansion of the overall program.

                                            54

                                                                   APPENDIX IV

                      Stringencies in funds and'manpower also have not
                 permitted compilation of environmental baseline or basic
                 habitat data studies essential for adequate compliance with
                 the Coordination Act and the National Environmental Policy
                 Act. Specifically, this means that environmental data is
                 far substandard to other project data on hydrology, engineer-
                 ing,.geology, economics, etc. Such an imbalance can con-
                 ceivably no, longer be tolerated under the new Water Resources
                 Council Principles and Standards which elevate environmental
                 factors to a level equal to national and regional economic
                 factors in project formulation and evaluations. Substantial
                 increases in funds and manpower are essential to carry out
                 BSF&W expanded responsibilities under the new Principles and
                 Standards.

                 NATIONAL MARINE FISHERIES SERVICE

                      Within NMFS, the Division of Water Resources Management
                 now carries out Coordination Act responsibilities with its
                 present authorized ceiling of 69 people. It also has responsi-
                 bility for the environmental statement review program, plus
                 heavy staff workloads related to review of:

                      --water quality criteria-,

                      --effluent guidelines;

                      --various guidelines, regulations, and policies of EPA,
                        AEC, and other Federal agencies;

                      --participation in special studies related to oil and
                        gas leasing on the outer continental shelf;

                      --studies of offshore nuclear powerplants;

                      --activities related to the Water Resources Planning
                        Act;

                      --coordination with BSF&W on guidelines and procedures;

                      --and a wide variety of other duties relating to enviTon-
                        mental matters.

                      NMFS started its program from a low base of funds and
                 manpower. Programs and staffs in the Columbia River Basin and

                                              55

                 APPENDIX IV

                 Alaska provided a nucleus in the western regions. Although
                 those, in general, are better staffed in relation to work-
                 load, a severe deficiency remains. However, the eastern
                 regions have the most massive workloads, hence the most severe
                 over commitment.

                      In the eastern regions, it has been possible to accom-
                 plish environmental statement reviews but only a fraction
                 of the necessary studies of section 10 permit applications.
                 There has been only nominal involvement with planning of the
                 major Federal projects, very limited involvement with FPC
                 licenses, and almost none with nuclear power projects. Few
                 of the 61,000 pending and probable National Pollutant Dis-
                 charge Elimination System permits, which need intensive study,
                 can be given adequate attention, nor can other permit pro-
                 grams.

                      The size of the workload substantially exceeds NMFS
                 manpower capabilities. It is particularly urgent that NMFS
                 expand its activities in the coastal zone with special ref-
                 erence to both commercial and sport species.

                      Constant surveillance, evaluation, and study are es-
                 sential to perpetuation of the irreplaceable estuarine and
                 coastal aquatic habitats. Proposed Federal and private de-
                 velopments threaten irreversible losses of these public re-
                 sources. The one chance to prevent such destruction is when
                 the permit application is reviewed. Also, as long as the
                 resource exists,, a new threat can arise at any time with a
                 new permit or construction proposal. The recovery of living
                 natural resources made possible by the cleanup of pollution,
                 must not be offset by destruction of the remaining natural
                 marshes and other estuarine habitat.

                                              56

                                                                                                             APPENDIX IV

                                                     BSF&W AND NMFS WORKLOAD STATISTICS

                                             FOR PERMITS, FEDERAL PROJECTS, AND OTHER STUDIES

                                                                                                              Fiscal year
                                                        Fiscal     Fiscal     Fiscal      Fiscal year              1974
                                                        year       year       year            1973             (estimated)
                                                        1970       1971       1972        NMFS   BSF&W       NMFS     BSF&W

                                                                                    (number)

                      PERMITS:
                          Corps (navigable
                            waters) (note a)            5,042      5,660      8,000      7,500    12,000     17,000   17,000
                          EPA, ocean dumping
                            (note b)                       -         -            -         13        -         Soo       500
                          EPA, NPDES  (note c)             -                      -      1,000     1,000     20,000   20,000
                          Other permits (note   d)         120        12S         80      300         110       300       120

                      PROJECTS AND OTHER STUDIES:
                          Corps projects                   127        197         171     299         310       300       300
                          Reclamation and other
                            projects                       80          43         54        39        117         40      120
                          Comprehensive studies              9           9          6         9         6         14        3
                          Special studies                  11          34         27        so        so          so      60
                          EIS reviews (note e)             -          200         356     496         500       600       900

                             Total                      5,389      6,268      8,688      9,706    14,093     38,804   39,008

                      aApplications for permits under section     10 of 1899  Rivers and Harbors Act and     section 404 of
                       Federal Water Pollution Control Act.

                      bSection 101 and 102 of Marine Protection, Research, and Sanctuaries Act (Ocean Dumping).

                      cNational Pollutant Discharge Elimination System, administered by EPA or State. Estimated
                       total number of applications and probable applications for initial permits is about
                       61,000 according to telephoned information from EPA, (Estimated 7,000 Public Notices issued
                       by January 1, 1974, 2.0,000 to be issued by June 30, 1974, and 61,000 to be issued by Decem-
                       ber 31, 1974.)

                      dIncludes the Bureau of Land Management, Forest Service, Bureau of Indian Affairs, FPC, and
                       AEC permits and licenses. (For NMFS, includes miscellaneous studies for other agencies.)

                      eReview of environmental impact statements required by the National Environmental Policy
                       Act of 1969.

                                                                          57

                         APPENDIX IV

                                                          BSF&W AND NMFS FUNDING FOR

                                                    WILDLIFE INVESTIGATION AND REPORTING

                                                       ON FEDERAL PROJECTS AND PERMITS

                                                     BSF&W funds                            NMFS funds
                                                                                     BSF&W
                      Fiscal                     Transfer      Other               Transfer                          Grand
                      year             Direct    (note a)    (note b)     Total    (note c)     Direct      Total    Total

                                                                       _(000 omitted)

                      1970              $1,768     $2,014       $509      $4,291     $ -        $         $ -        $4,291
                      1971              2,193      2,009        495       4,697         27S         433       708    S,13n
                      1972              3,394      1,711        524       5,629         275         433       708    6,062
                      1973              4,614      2,253        668       7,535         27S         704       969    8,239
                      1974(note d)      4,343      2,42S        691       7,4S9         1         1,452     1,452    8,911

                      aThe Coordination Act   authorizes Federal development      agencies to transfer funds for wild-
                       life studies.

                      bReimbursable funds for Comprehensive River Basin and other special studies.

                      CAmounts shown are included in BSF&W total..

                      dEstimated.

                                                                       APPENDIX IV

                                    BSF&W AND NMFS MANPOWER FOR

                              WILDLIFE INVESTIGATION AND REPORTING

                                  ON FEDERAL PROJECTS AND PERMITS

                                              Personnel
                              Fiscal
                              year        BSF&W        NMFS       Total

                              1970          233          a2,        258
                              1971          271          30         301
                              1972          291          30         321
                              1973          333          59         392
                              1974          342          69         411

                                    ESTIMATED PERSONNEL NEEDED
                                   FOR FISCAL  YEAR 1974  WORKLOAD

                                                  Estimated         Additional
                                    Actual           need             needed

                        NMFS          69              267              198
                        tSF&W        342              750              408

                            Total    411            1,017              606

                  aBefore fiscal year   1971, BSF&W   financed a staff of about
                    25 people, which the Bureau of    Commercial Fisheries main"
                    tained for reporting on Federal projects and permits.

                                                59

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