Land Management Agencies: Restoring Fish Passage Through Culverts
on Forest Service and BLM Lands in Oregon and Washington Could	 
Take Decades (23-NOV-01, GAO-02-136).				 
								 
The Bureau of Land Management and the Forest Service manage over 
41 million acres of federal lands in Oregon and Washington,	 
including 122,000 miles of roads that use culverts--pipes or	 
arches made of concrete or metal--to allow water to flow from one
side of the road to the other. Many of the streams that pass	 
through these culverts are essential habitat for fish and other  
aquatic species. Over 10,000 culverts exist on fish-bearing	 
streams in Oregon and Washington, though the number that impede  
fish passage is unknown. Ongoing agency inventory and assessment 
efforts have identified nearly 2,600 barrier culverts, but agency
officials estimate that more than twice that number may exist.	 
Although the agencies recognize the importance of restoring fish 
passage, several factors inhibit their efforts. Most		 
significantly, the agencies have not made sufficient funds	 
available to do all the culvert work necessary. In addition, the 
often lengthy process of obtaining federal and state		 
environmental clearances and permits, as well as the short	 
seasonal "window of opportunity" to do the work, affects the	 
agencies' ability to restore fish passages quickly. Furthermore, 
the shortage of experienced engineering staff limits the number  
of projects that can be designed and completed. BLM and the	 
Forest Service have completed 141 culvert projects to remove	 
barriers and to open an estimated 171 miles of fish habitat from 
fiscal year 1998 through 2000. Neither agency, however, knows the
extent to which culvert projects ultimately result in improved	 
fish passage because neither agency requires systematic 	 
post-project monitoring to measure the outcomes of their efforts.
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-02-136 					        
    ACCNO:   A02486						        
  TITLE:     Land Management Agencies: Restoring Fish Passage Through 
Culverts on Forest Service and BLM Lands in Oregon and Washington
Could Take Decades						 
     DATE:   11/23/2001 
  SUBJECT:   Anadromous fishes					 
	     Land management					 
	     Road construction					 
	     Funds management					 
	     INFISH						 
	     PACFISH						 
	     Pacific Northwest Forest Plan			 
	     BLM Jobs In The Woods Program			 
	     Washington Fish Passage Barrier Removal		 
	     Program						 								 
	     Washington 					 
	     Oregon						 

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GAO-02-136
     
Report to the Ranking Minority Member, Subcommittee on Interior and Related
Agencies, Committee on Appropriations, House of Representatives

United States General Accounting Office

GAO

November 2001 LAND MANAGEMENT AGENCIES

Restoring Fish Passage Through Culverts on Forest Service and BLM Lands in
Oregon and Washington Could Take Decades

GAO- 02- 136

Page i GAO- 02- 136 Culvert Fish Passage Letter 1

Results in Brief 1 Background 3 Extent to Which Barrier Culverts Block Fish
Passage Is Unknown 5 Several Factors Affect Agencies' Ability to Eliminate
Barrier

Culverts Quickly 9 Ultimate Effectiveness of Agency Efforts to Restore Fish
Passage

Is Largely Unknown Because Completed Projects Are Not Systematically
Monitored 15 Conclusions 20 Recommendation for Executive Action 20 Agency
Comments 20

Appendix I Barrier Culvert Information by Bureau of Land Management District
Office and National Forest 22

Bureau of Land Management 22 Forest Service 23

Appendix II Comments From the Department of the Interior 25

Appendix III Comments From the Forest Service 26

Appendix IV Scope and Methodology 27

Appendix V GAO Contact and Staff Acknowledgments 29 GAO Contact 29
Acknowledgments 29

Tables

Table 1: BLM Fish Passage Barrier Culverts as of August 2001 23 Table 2:
Forest Service Fish Passage Barrier Culverts as of

August 2001 24 Contents

Page ii GAO- 02- 136 Culvert Fish Passage Figures

Figure 1: Culvert Before and After Replacement 5 Figure 2: Total Culverts
Assessed and Barriers Estimated on BLM

and Forest Service Lands as of August 1, 2001 7 Figure 3: Sources of Funding
for BLM Culvert Projects, Fiscal

Years 1998 Through August 1, 2001 11 Figure 4: Source of Funding for Forest
Service Culvert Projects,

Fiscal Years 1998 Through August 1, 2001 12 Figure 5: Completed BLM and
Forest Service Culvert Projects by

Fiscal Year 16

Page 1 GAO- 02- 136 Culvert Fish Passage

November 23, 2001 The Honorable Norm Dicks Ranking Minority Member
Subcommittee on Interior

and Related Agencies Committee on Appropriations House of Representatives

Dear Mr. Dicks: The Bureau of Land Management, within the Department of the
Interior, and the Forest Service, within the U. S. Department of
Agriculture, manage over 41 million acres of federal lands in Oregon and
Washington, including 122,000 miles of roads that use culverts-- pipes or
arches made of concrete or metal- to allow water to flow from one side of
the road to the other. Many of the streams that pass through these culverts
are essential habitat for fish and other aquatic species. When culvert
openings are too high above the streams for fish to jump into or culverts
are positioned at a grade too steep for fish to ascend, they pose barriers
to fish attempting to access their natural rearing and spawning habitat.
Passage through culverts is particularly important to anadromous fish, such
as Coho and Chinook salmon (some of which are threatened or endangered),
which are spawned in freshwater streams, but must travel to the ocean to
mature, then travel back to the streams to spawn. The two agencies are
concerned about the condition of the culverts on fish bearing streams on
their Oregon and Washington lands because many, either because of
deterioration or design, do not provide passage for all life stages
(juvenile to adult) as required by current standards.

In this context, you asked us to determine (1) the number of culverts that
may impede fish passage on Bureau of Land Management and Forest Service
lands in Oregon and Washington, (2) the factors affecting the agencies'
ability to restore passage through culverts acting as barriers to fish
(hereafter referred to as barrier culverts), and (3) the results of the
agencies' efforts to restore fish passage.

Over 10,000 culverts exist on fish- bearing streams in Oregon and Washington
according to Bureau of Land Management and the Forest Service estimates, but
neither agency knows the total number that impede fish passage. Ongoing
agency inventory and assessment efforts have

United States General Accounting Office Washington, DC 20548

Results in Brief

Page 2 GAO- 02- 136 Culvert Fish Passage

already identified nearly 2,600 barrier culverts, but agency officials
estimate that more than twice that number may exist. The Forest Service
plans to complete its assessment by the end of calendar year 2001. The
Bureau of Land Management has not set a specific completion date for
assessing all culverts, but intends to continue assessing culverts as part
of its ongoing land management planning efforts. According to officials,
both agencies intend to use the assessments to assist them in planning and
setting priorities for eliminating barrier culverts. Based on current
assessments, the agencies estimate that efforts to restore fish passage may
ultimately cost over $375 million and take decades.

Although the agencies recognize the importance of restoring fish passage,
several factors are inhibiting agencies' efforts. Most significantly, the
agencies have not made sufficient funds available to do all the culvert
project work necessary. In allocating road maintenance funds, the agencies
assign a relatively low priority to such fish passage projects because road
safety is a higher priority than resource protection. As a result, the
agencies allocate most maintenance funding to address their large road
maintenance backlogs rather than to undertake culvert projects. In addition,
the often lengthy process of obtaining federal and state environmental
clearances and permits to perform culvert work, as well as the short
seasonal "window of opportunity" to do the work, affects the agencies'
ability to restore fish passages quickly. Furthermore, the shortage of
experienced engineering staff limits the number of projects that the
agencies can design and complete. Currently, each barrier removal project
generally takes 1 to 2 years from start to finish.

The Forest Service and the Bureau of Land Management completed 141 culvert
projects from fiscal year 1998 through August 1, 2001, to remove barriers to
anadromous fish and to open an estimated 171 miles of fish habitat. Neither
agency, however, knows the extent to which culvert projects ultimately
result in improved fish passage because neither agency requires systematic
post- project monitoring to measure the outcomes of their efforts. The
agencies say they do not perform post- project monitoring because of limited
funding and staff availability and, according to agency officials, because
they assume culverts built using current standards on lands under their
jurisdiction should allow fish passage. State and local entities using these
same standards, however, require systematic postproject monitoring to ensure
that they used the most effective methods for improving fish passage under
various conditions. Oregon's monitoring results, for example, indicate that
retrofitting culverts with devices that slow the flow of water can
effectively restore fish passage. Without monitoring, neither the Forest
Service nor the Bureau of Land

Page 3 GAO- 02- 136 Culvert Fish Passage

Management can ensure that the federal moneys expended to improve fish
passage are actually achieving the intended purpose. This report recommends
that both agencies develop guidance for systematically assessing completed
barrier removal projects to determine whether they are improving fish
passage as intended. The agencies agreed with our recommendation for
systematic monitoring.

The Bureau of Land Management (BLM) and the Forest Service manage most of
the nation's 655 million acres of federal land. BLM is responsible for about
264 million acres of public lands, managed by 12 state offices that are
responsible for supervising the operations of 175 field offices nationwide.
The Forest Service is responsible for about 192 million acres of public
lands, managed by 9 regional offices that are responsible for supervising
the operations of 155 national forests.

BLM and the Forest Service manage about 93 percent of the 44 million acres
of federally owned land in Oregon and Washington. BLM's Oregon State Office
manages about 17 million acres of land in the two states, including over
28,000 miles of roads. The state office directs the operations of 10
district offices- 9 in Oregon and 1 in Washington-- each responsible for
managing BLM's public land resources within its geographic jurisdiction. Six
of the Oregon districts contain Oregon and California Grant Lands,
distributed in a checkerboard pattern within each district, and interspersed
within and around the federal lands is state and private lands. The Forest
Service's Region 6 manages about 25 million acres of land in the two states,
including nearly 94,000 miles of roads. Region 6 directs the operations of
19 national forests- 13 in Oregon and 6 in Washington. BLM's district
offices and the Forest Service's national forest offices perform similar
land management functions, including restoration of fish and wildlife
habitat and designing, constructing, and maintaining roads. 1

BLM and Forest Service land management activities regarding fish habitat in
Oregon and Washington are governed by three regional agreements: the
Northwest Forest Plan, signed in 1994 for activities on the west side of the
Cascade mountain range, and PACFISH and INFISH, signed in 1995, for

1 Unless otherwise stated, this report focuses on the activities of BLM's
Oregon State Office and districts and the Forest Service's Pacific Northwest
Region 6 and corresponding forests. Background

Page 4 GAO- 02- 136 Culvert Fish Passage

activities on the east side of the range. 2 Both agencies are required to
direct their land management activities toward achieving the objectives of
the three agreements. The Northwest Forest Plan's Aquatic Conservation
Strategy includes the objective of maintaining and restoring "connectivity
within and between watersheds," which must provide "unobstructed routes to
areas critical for fulfilling the life history requirements" of aquatic
species. 3 In addition, the Northwest Forest Plan's road management
guidelines state that the agencies shall "provide and maintain fish passage
at all road crossings of existing and potential fish- bearing streams." 4
PACFISH includes the objective of achieving "a high level of habitat
diversity and complexity? to meet the life- history requirements of the
anadromous fish community inhabiting a watershed." The PACFISH road
management guidelines duplicate the Northwest Forest Plan guidance. INFISH
provides similar management objectives and guidance for resident native fish
outside of anadromous fish habitat.

Maintaining fish passage and habitat is particularly important for
anadromous fish, which as juveniles migrate up and down stream channels
seasonally, then travel from their freshwater spawning grounds to the ocean
where they mature, and finally return to their spawning grounds to complete
their life cycle. Under the authority of the Endangered Species Act, the
National Marine Fisheries Service currently lists four species of salmon-
including Coho, Chinook, Chum, and Sockeye- as well as steelhead and sea-
run trout as either threatened or endangered anadromous fish in the
northwest region. According to agency officials, BLM and Forest Service
lands in Oregon and Washington include watersheds that represent some of the
best remaining habitat for salmon and other aquatic life, often serving as
refuge areas for the recovery of listed species. As such, unobstructed
passage into and within these watersheds is critical.

2 PACFISH is the common title for the Decision Notice/ Decision Record,
Environmental Assessment, and Finding of No Significant Impact for interim
management of anadromous fish producing watersheds on federal lands in
eastern Oregon and Washington, Idaho, and portions of California. The Inland
Native Fish Strategy (INFISH) is PACFISH's counterpart for resident native
fish outside of anadromous fish habitat.

3 A watershed is an area of land that acts as a drainage basin contributing
water, organic matter, nutrients, and sediments to a stream or lake. 4 Fish-
bearing streams support fish during all or a portion of a typical year.

Page 5 GAO- 02- 136 Culvert Fish Passage

Culverts-- generally pipes or arches made of concrete or metal-- are
commonly used by BLM and the Forest Service to permit water to flow beneath
roads where they cross streams, thereby preventing road erosion and allowing
the water to follow its natural course. Culverts come in a variety of shapes
and sizes, designed to fit the circumstances at each stream crossing, such
as the width of the stream or the slope of the terrain. Historically, agency
engineers designed culverts for water drainage and passage of adult fish.
However, as a culvert ages, the pipe itself and conditions at the inlet and
outlet can degrade such that even strong swimming adult fish cannot pass
through the culvert. The agencies remove, repair, or replace culverts to
restore fish passage, as shown in figure 1.

Figure 1: Culvert Before and After Replacement

Source: BLM's Eugene District Office.

To meet the objectives of the Northwest Forest Plan and PACFISH, as well as
Oregon and Washington state standards, current culvert repair or replacement
efforts must result in a culvert that allows the passage of all life stages
of fish, from juvenile to adult.

As of August 1, 2001, the agencies' fish passage assessments identified
almost 2,600 barrier culverts- over 400 on BLM lands and nearly 2,200 on
Forest Service lands-- and agency officials estimate that, in total, up to
5,500 fish barrier culverts may exist. BLM's 10 district offices are
collecting culvert information as part of their ongoing watershed analysis
activities and have not established a date for completing all culvert
assessments. The Forest Service, using a regionwide fish passage assessment
protocol, plans to complete data collection for all of its 19 Extent to
Which

Barrier Culverts Block Fish Passage Is Unknown

Page 6 GAO- 02- 136 Culvert Fish Passage

forests by the end of calendar year 2001. The culvert information the
agencies are collecting will help them coordinate and prioritize culvert
repair, replacement, and removal efforts. Based on their current knowledge
of culvert conditions, the agencies project that to restore fish passage at
all barrier culverts could cost over $375 million and take decades to
finish.

BLM's district offices are assessing fish passage through culverts as part
of the ongoing land management activity of a watershed analysis. A watershed
analysis-- a systematic procedure to characterize the aquatic (in- stream),
riparian (near stream) and terrestrial (remaining land area) features within
a watershed-- is a requirement of the Northwest Forest Plan and provides the
foundation for implementing stream and river enhancement projects, timber
sales, and road building and decommissioning projects. According to an
agency official, the extent to which a watershed analysis has been completed
varies by district. The five western Oregon districts entirely within the
Northwest Forest Plan's jurisdiction, which contain 98 percent of BLM's
culverts on fish- bearing streams, have completed watershed analyses for 87
to 100 percent of their lands. The range for the remaining five districts is
0 to 18 percent. Each BLM district office maintains its own records
regarding barrier culverts on its lands. As of August 1, 2001, BLM's
district offices had assessed 1,152 culverts for fish passage and identified
414 barrier culverts. BLM plans to continue its ongoing watershed analysis
process, and estimates, based on assessments to date, that an additional 282
barrier culverts may be identified, for a total of 696 culverts blocking
fish passage.

The Forest Service initiated a regionwide assessment of culverts on fish-
bearing streams in fiscal year 1999 to determine the scope of fish passage
problems and to create a database of culvert information that will allow it
to prioritize projects to address barrier culverts on a regionwide basis.
The region first developed written guidance and provided implementation
training to staff at each forest office. In fiscal year 2000, 13 of the 19
forests conducted the assessments and reported the results to the region's
fish passage assessment database. In fiscal year 2001, the remaining six
forest offices initiated their assessments and follow- up and verification
of the first year's results is ongoing. As of August 2001, the forest
offices had assessed 2,986 culverts for fish passage and identified 2,160-
or about 72 percent- as barrier culverts. The region plans to complete its
assessment by December 2001, and based on its findings thus far, estimates
that an additional 2,645 barrier culverts may be identified, for a total of
4,805 culverts blocking fish passage. Agencies' Assessments to

Determine Maintenance Status of Culverts Are Ongoing

Page 7 GAO- 02- 136 Culvert Fish Passage

On the basis of information collected as of August 1, 2001, the two agencies
estimate a total of 10,215 culverts on fish- bearing streams under their
jurisdictions- 2,822 culverts on BLM lands and 7,393 culverts on Forest
Service lands- as shown in figure 2.

Figure 2: Total Culverts Assessed and Barriers Estimated on BLM and Forest
Service Lands as of August 1, 2001

Source: BLM's Oregon State Office and the Forest Service's Region 6.

Detailed information on district and forest office culvert assessment
efforts is provided in appendix I.

Additional ground work is necessary before both agencies have complete
information on the extent of barrier culverts on their Oregon and Washington
lands, and as such, neither agency has established a process for
prioritizing passage restoration projects on a regionwide basis. However,
the agencies are using the fish passage information they have Assessment
Results Will

Help Prioritize Reduction of Barrier Backlog

Page 8 GAO- 02- 136 Culvert Fish Passage

collected to help them coordinate and prioritize culvert repair,
replacement, and removal efforts on a more limited scale.

For example, officials at BLM's Coos Bay district stated that through the
ongoing culvert assessment process, they annually reprioritize culvert
projects for each resource area within the district and for each watershed
within each resource area, thus ensuring that the most critical barriers are
addressed first. In addition, according to BLM state office officials, some
culverts identified by district offices as fish passage barriers are
included in their deferred maintenance and capital improvement project
backlog and evaluated for funding among other road and facility projects.
State office officials stated that while culvert passage restoration
projects have not ranked high due to the critical nature of other backlog
projects, they expect barrier culvert projects to move up the list for
funding as the backlog is reduced.

National forest offices use their culvert fish passage assessment
information to assist them in prioritizing culvert maintenance activities
and for broader road management planning purposes. For example, in fiscal
year 2001, regional officials directed each forest office to identify its
top five culvert passage restoration projects when submitting its final
assessment report. The region considered these projects for funding;
however, according to a regional office official, it is not known how many
of these projects were actually completed. In addition, Olympic National
Forest officials stated that they have developed a draft road management
strategy that uses the fish passage assessment results as input to assist
them in further prioritizing of road projects identified by the strategy.

Although BLM and the Forest Service are currently addressing barrier
culverts based on the assessment information they have collected, agency
officials estimate, based on their results to date, that it may cost over
$375 million and take decades to restore fish passage at all barrier
culverts. BLM officials estimate a total cost of approximately $46 million
to eliminate their backlog of about 700 barrier culverts, while Forest
Service officials estimate a total cost of about $331 million to eliminate
their backlog of approximately 4,800 barrier culverts. At the current rate
of replacement, BLM officials estimate that it will take 25 years to restore
fish passage through all barrier culverts, and Forest Service officials
estimate that they will need more than 100 years to eliminate all barrier
culverts. Furthermore, these estimates do not reflect any growth in the
backlog due to future deterioration of culverts that currently function
properly.

Page 9 GAO- 02- 136 Culvert Fish Passage

According to BLM and Forest Service officials, several factors restrict
their ability to quickly address the long list of problem culverts. Of most
significance, the agencies assign a relatively low priority to such culvert
projects when allocating road maintenance funds because ensuring road safety
is the top priority for road maintenance, repair, and construction funds.
Both agencies emphasize reducing the backlog of road maintenance rather than
specifically correcting barrier culverts. Because neither agency requests
funds specifically for barrier culvert projects, district and forest offices
must fund these restoration projects within their existing budgets, and
these projects must compete with other road maintenance projects for the
limited funds. Therefore, to restore fish passage, the agencies largely rely
on other internal or external funding sources not dedicated to barrier
removal nor guaranteed to be available from year- to- year. Other factors
affecting the agencies' efforts to restore fish passage include the complex
and lengthy federal and state project approval process to obtain
environmental clearances and the limited number of agency engineers
experienced in designing culverts that meet current fish passage
requirements. Furthermore, to minimize disturbance to fish and wildlife
habitat, states impose a short seasonal "window of opportunity" within which
restoration work on barrier culverts can occur. As a result, each barrier
removal project generally takes 1 to 2 years from start to finish.

Both BLM and the Forest Service regard culverts as a component of their road
system- similar to bridges, railings, signs, and gates- each requiring
maintenance, including repair, replacement, and removal to ensure safe
operation. As such, each agency requests funding for road maintenance as a
total program of work rather than requesting funding specifically for
culvert maintenance, or more specifically, to restore fish passage at
barrier culverts. Furthermore, according to agency guidance, ensuring road
safety is the top priority for road maintenance activities rather than
removing barrier culverts.

Individual forest and district offices must fund culvert projects within
their road maintenance allocations, compete with other units for deferred
maintenance funds, or use other funding sources. BLM's state office and the
Forest Service's regional office each allocate annual road maintenance funds
to districts and forests primarily based on the miles of roads each contains
and distribute additional funds to those units for maintenance projects on a
competitive basis. BLM's fiscal year 2001 annual road maintenance funding
totaled about $6 million, while according to officials, about $32 million is
required to meet annual maintenance needs, including culverts. The Forest
Service's fiscal year 2001 annual road maintenance Several Factors Affect

Agencies' Ability to Eliminate Barrier Culverts Quickly

Barrier Culvert Projects Compete With Other Road Maintenance Priorities for
Limited Funding

Page 10 GAO- 02- 136 Culvert Fish Passage

funding totaled about $32 million, while according to officials, about $129
million is required to meet their annual maintenance needs, including
culverts. Due to their large backlogs of deferred maintenance, officials of
both agencies stated that deferred maintenance funds have not been
distributed to district or forest offices for fish passage restoration
projects.

In the absence of sufficient road maintenance funding, the district and
forest offices largely rely on other internal or external funding sources
not specifically dedicated to barrier removal nor guaranteed to be available
from year- to- year to restore anadromous fish passage at barrier culverts.
As shown in figure 3, BLM's district offices reported that since fiscal year
1998, they relied almost entirely on Jobs- In- The- Woods program funding,
which seeks to support displaced timber industry workers within BLM's Oregon
and California Grant Lands. BLM distributes this funding to the western
districts in Oregon containing the Oregon and California Grant Lands to fund
contracts with local workers to do stream restoration projects, including
barrier culvert repair and replacement. While BLM officials view the Jobs-
In- The- Woods program as an ongoing source of funding for culvert projects,
this funding source is not dedicated to barrier removal and BLM may use
these funds for a variety of other resource programs or projects. Other BLM
barrier culvert project funding sources include timber sales and the Federal
Highway Administration's Emergency Relief for Federally- owned Roads to
replace storm- damaged culverts.

Page 11 GAO- 02- 136 Culvert Fish Passage

Figure 3: Sources of Funding for BLM Culvert Projects, Fiscal Years 1998
Through August 1, 2001

Source: BLM's Oregon State Office.

As shown in figure 4, national forest offices reported that since fiscal
year 1998 they have primarily relied on the Federal Highway Administration's
funding and the National Forest Roads and Trails funds for projects to
restore anadromous fish passage at barrier culverts. Due to severe flooding
in recent years and widespread damage to culverts, forest offices obtained
Federal Highway Administration funds to replace damaged culverts and
concurrently ensure these culverts meet current fish passage standards.
While such funds enabled the forest offices to address barrier culverts, the
forest offices cannot rely on future flood events to ensure a steady stream
of funding for such projects. National Forest Roads and Trails funds consist
of 10 percent of the receipts of the national forests made available to
supplement annual appropriations for road and trail construction and
projects that improve forest health conditions. Forest offices used these
funds to restore fish passage at barrier culverts and to fund their ongoing
culvert fish passage assessment effort. These funds,

Page 12 GAO- 02- 136 Culvert Fish Passage

however, are not dedicated to fish passage projects, but rather culvert
projects compete with other road projects for these funds on a regionwide
basis. Other funding sources for Forest Service fish passage projects
include Jobs- In- The- Woods and timber sales. 5

Figure 4: Source of Funding for Forest Service Culvert Projects, Fiscal
Years 1998 Through August 1, 2001

Source: The Forest Service's Region 6.

5 According to Forest Service officials, Jobs- In- The- Woods funds are no
longer available.

Page 13 GAO- 02- 136 Culvert Fish Passage

In addition to limitations on the amount of funding available for barrier
culvert projects and uncertainty regarding the continuity of such funding,
three other factors affect the agencies' efforts to restore fish passage.
These factors are (1) the complex and lengthy federal and state project
approval process, (2) the limited number of agency engineers with experience
designing culverts that meet current fish passage standards, and (3) the
short seasonal "window of opportunity" during which work on barrier culverts
can occur. Each of these factors affects the time frame needed to complete
each of the major phases of a barrier culvert project- specifically,
obtaining necessary permits and clearances, designing the culvert, and
constructing the culvert- and consequently impacts the number of projects
that can be completed annually. Due to these factors, culvert projects to
restore culvert fish passage take 1 to 2 years to complete, according to BLM
and Forest Service officials.

First, BLM and Forest Service officials stated that the number of fish
passage projects the agencies can undertake and the speed with which they
can be completed depend largely on how long it takes to obtain the various
federal and state clearances necessary to implement a culvert project. Under
the National Environmental Policy Act, an assessment of each project's
impact on the environment must be completed before construction can
commence. If the assessment indicates that an endangered species may be
adversely affected by the project, Section 7 of the Endangered Species Act
of 1973 requires the agency to consult with the appropriate authority-
generally the National Marine Fisheries Service for anadromous fish and the
Fish and Wildlife Service for other species- to reach agreement on how to
mitigate the disturbance. BLM and the Forest Service have entered into an
agreement with the consulting agencies to expedite the process through
streamlined procedures. However, according to agency representatives,
factors such as staffing shortages and turnover, as well as differing
interpretations of the streamlining guidance, have prevented the revised
consultation process from producing the efficiencies desired by the
agencies, and it is currently under review. In addition to consultation:

 the U. S. Army Corps of Engineers requires a permit for fill or excavation
in waterways and wetlands;

 Oregon requires a "removal and fill" permit for in- stream construction;
and

 Washington requires a hydraulic project permit to engage in construction
activities within streams.

According to information provided by district and forest offices for 56
completed culvert projects, the clearance and permit process is the most
Factors Affecting Project

Design, Approval, and Construction Restrict Agencies' Efforts to Eliminate
Barriers

Page 14 GAO- 02- 136 Culvert Fish Passage

time- consuming phase of a culvert project, ranging from a low of 4 weeks to
a high of 113 weeks, for an average of about 31 weeks.

Second, BLM's and the Forest Service's efforts to eliminate barrier culverts
are restricted, according to agency officials, by the limited number of
engineers available to design them, and more specifically, the few with
experience in designing culverts that meet current fish passage
requirements. As a result, district and forest officials speculate that
additional hiring or contracting with engineering firms for culvert design
work may be necessary if greater emphasis is placed on reducing the barrier
culvert backlog. Agency officials also emphasized the need for more fish
biologists, hydrologists, and other professionals with fish passage design
skills. According to time frame information provided by district and forest
offices for 56 completed culvert projects, the design process is the second
most time- consuming phase of a project, ranging from a low of 4 weeks to a
high of 78 weeks to complete, for an average of about 19 weeks.

Finally, BLM and Forest Service officials stated that their efforts to
eliminate barrier culverts are limited by a short seasonal "window of
opportunity" of about 3 months during which fish passage restoration work-
that is, construction work within streams- can occur. Oregon and Washington
have established these time frames to minimize the impacts to important
fish, wildlife, and habitat resources. The summer to fall instream work time
frames, when construction is most feasible due to low water flow, most
commonly run from July to September, but could be as narrow as July 15 to
August 15, or just 1 month. According to time frame information provided by
district and forest offices for 56 completed culvert projects, construction
is the least time- consuming phase of a project, ranging from a low of 4
weeks to a high of 61 weeks to complete, for an average of about 10 weeks.

According to BLM and Forest Service officials, the minimum time necessary to
complete a barrier culvert project, if all phases of the project are
completed in the shortest possible time frame, is about 1 year. However, due
to the factors discussed above, projects are more likely to take over a year
to complete. The consequences of a delay caused by any one of the factors
have a cascading effect on the project completion date. For example,
according to agency officials, they generally begin a project by initiating
the clearance and permit process and collecting some preliminary engineering
information. However, if project clearances are not obtained or imminent by
March when project funding decisions are made, construction may be put off
to the next year, rather than committing

Page 15 GAO- 02- 136 Culvert Fish Passage

funds to a project that may not be ready for implementation within the
seasonal time frames. Similarly, project clearances may be completed timely,
but the project may be delayed if an engineer with fish passage design
experience is not available. And, if all phases of a project, including
construction contracts, are not in place in time to complete construction
within the state- mandated stream construction time frames, the project must
be put off until the next season. According to the information provided by
district and forest offices for 56 projects, the total time to complete a
project ranged from a low of 16 weeks to a high of 186 weeks, for an average
of 60 weeks.

BLM and the Forest Service completed 141 projects to restore fish passage
for anadromous fish at barrier culverts from fiscal year 1998 through July
2001 and opened access to an estimated 171 miles of fish habitat. However,
because neither agency requires systematic monitoring of these completed
projects, the actual extent of improved fish passage is largely unverified.
According to agency officials, current culvert fish passage design standards
are based on scientific research that considers such factors as the swimming
ability of fish at various life stages and the velocity of water. Therefore,
the officials assume that fish can migrate into the newly accessible habitat
through culverts built to these standards. Furthermore, agency officials
cite a lack of funds and available staff as reasons for not requiring
systematic post- project monitoring.

While district and forest offices may monitor projects on a limited or ad
hoc basis, whether both juvenile and adult fish can actually pass through
the restored culvert or actually inhabit the upstream areas is not
systematically determined. However, the Oregon and Washington state fish
passage restoration programs, as well as other local efforts, require
systematic post- project monitoring to determine the most effective methods
for improving fish passage under various conditions. Without such
monitoring, neither the Forest Service nor BLM can ensure that the federal
moneys expended for improving fish passage are actually achieving the
intended purpose.

As shown in figure 5, BLM reported 68 projects completed to restore fish
passage for anadromous fish at barrier culverts from fiscal year 1998
through August 1, 2001, opening access to an estimated 95 miles of fish
habitat. During the same time frame, the Forest Service reported 73 projects
completed to restore fish passage for anadromous fish at barrier culverts
and opened access to an estimated 76 miles of fish habitat. Ultimate

Effectiveness of Agency Efforts to Restore Fish Passage Is Largely Unknown
Because Completed Projects Are Not Systematically Monitored

Forest Service and BLM Do Not Require Post- Project Monitoring

Page 16 GAO- 02- 136 Culvert Fish Passage

Figure 5: Completed BLM and Forest Service Culvert Projects by Fiscal Year

Note: Fiscal year 2001 includes only projects completed as of August 1,
2001. Source: BLM's Oregon State Office and the Forest Service's Region 6.

The actual extent of improved fish passage is largely unknown, however,
because neither agency requires systematic post- project monitoring of
completed projects. Forest and district offices undertake a wide range of
activities in and around streams to restore aquatic habitat. These
activities include eliminating fish passage barrier culverts, as well as
other activities such as stabilizing eroding stream banks, planting
vegetation, and placing desirable woody debris and boulders into the
streams. While each forest and district office is required to conduct
monitoring of selected restoration activities, neither agency specifically
requires barrier culvert projects be monitored. Therefore, restoration
projects selected by district and forest offices for monitoring may or may
not include barrier culvert passage projects. Consequently, the agencies do
not systematically determine whether fish can actually pass through repaired
or replaced

Page 17 GAO- 02- 136 Culvert Fish Passage

culverts. Furthermore, while the miles of habitat theoretically made
accessible to fish is estimated, the extent to which fish actually inhabit
that stream area is not routinely determined.

BLM and Forest Service officials stated that monitoring all culvert fish
passage projects would be a costly and time- consuming effort for their
already limited staff. Therefore, district and forest staff stated that
culvert project follow- up is generally ad hoc in nature. For example,
subsequent to project completion, the designing engineer will likely look to
see if water appears to be flowing through the culvert as designed, or the
fish biologist that helped plan a project may walk up the stream side
looking for egg beds to ascertain the presence of fish. However, according
to agency officials, a formalized, comprehensive measurement of results, for
example, requiring engineers to measure water flows through all completed
culverts or biologists to count egg beds in every area of a newly opened
habitat is not feasible at current funding and staffing levels. One forest
official stated that ideally, every project should have monitoring funds
included with the project funds to verify effectiveness, but funding
realities have not made this possible.

According to BLM and Forest Service officials, in the absence of systematic
monitoring, they assume that culverts built to current standards will allow
fish migration into the newly accessible habitat. Current culvert design
standards are based on scientific research that considers important factors
such as the swimming capabilities of fish at various life stages and the
velocity of water to guide engineers in building culverts that will allow
passage of juvenile to adult fish. BLM primarily follows the standards
published by the Oregon State Department of Fish and Wildlife, and the
Forest Service follows those same Oregon standards or the Washington
Department of Fish and Wildlife's standards, depending on the project's
location. Where appropriate, the current standards endorse the use of open
bottom culverts that simulate natural stream bottoms and slopes and culvert
widths that adhere to the stream's natural width, mimicking the stream's
natural features to the greatest extent possible.

However, even culvert projects built to current standards may not
necessarily result in improved fish passage. District and forest officials
characterized culvert fish passage design as an evolving area of study. For
example, according to federal and state officials, retrofitting culverts by
adding staggered or perforated panels inside to slow down water velocities
is a complex design process only applicable in limited circumstances.
Another area of concern, according to Forest Service

Page 18 GAO- 02- 136 Culvert Fish Passage

officials, is the length of culverts because questions remain as to how far
fish will swim inside a dark culvert. Furthermore, during our field visits
to completed culvert project sites, we observed culverts that, according to
agency officials, continued to be barriers to fish passage, including a
retrofitted culvert that did not sufficiently slow water flow, a replaced
pipe that did not allow juvenile fish passage, and a culvert that allowed
water to flow under it rather than through it.

Systematic post- project monitoring is a requirement of the Oregon and
Washington state fish passage restoration efforts on state lands, as well as
cooperative local programs on other lands within the states and has helped
these programs to identify ways to enhance the effectiveness of fish passage
projects. According to an Oregon Department of Fish and Wildlife official,
in fiscal year 1999 the state implemented a protocol for systematically
monitoring and documenting the results of culvert retrofit projects to
improve fish passage. The protocol, jointly developed by Oregon's Department
of Fish and Wildlife and Department of Transportation, requires monitoring
the movement of water in and around retrofitted culverts to determine if
fish passage is improved. In the first year of implementation, the agencies
systematically monitored selected culverts retrofitted in 1998 within
certain state regions, including visual inspections and water velocity
measurements taken at different times to assess how well the retrofit
designs slowed water velocity. The monitoring results indicated the retrofit
designs, while needing some adjustments, improved fish passage by slowing
water and reducing culvert entry jump heights for fish. According to the
state official, the agencies are currently developing fish passage
monitoring protocols for culverts that have been replaced rather than
retrofitted.

The Washington Department of Fish and Wildlife, in partnership with the
state Department of Transportation, developed and implemented a threelevel
culvert and fish use evaluation procedure for all culvert retrofit or
replacement projects funded by the state's Fish Passage Barrier Removal
Program. Agreeing that the best management practice is to avoid "walking
away" from a fish passage project once construction is complete, the
agencies are systematically assessing culvert projects for design,
durability and efficiency; determining if fish use the newly available
habitat; and troubleshooting problems identified. The three- level
evaluation involves the following steps:

 First, fish use before and after project completion is determined, and
each completed project is evaluated for durability, efficiency, and design
flaws, Post- Project Monitoring

Could Help Identify the Most Effective Fish Passage Restoration Methods

Page 19 GAO- 02- 136 Culvert Fish Passage

which are corrected during the year following project completion. The
culvert is removed from the monitoring list if fish passage is verified and
no additional monitoring is required.

 Second, for culverts where fish passage is not occurring, additional
monitoring for fish presence is implemented, and if necessary, other methods
to support fish recovery, including supplementation such as planting of
hatchery fish, fishing restrictions, or stream habitat improvement projects,
are implemented.

 Third, selected culverts are studied to determine the overall impact on
fish populations.

Evaluation results as of April 2001 indicated most habitats reclaimed
through culvert projects were immediately populated by fish; however, varied
responses on some streams require additional monitoring and possibly further
enhancement efforts to promote fish recovery.

In addition to the state monitoring efforts, local fish passage restoration
plans may also require systematic monitoring of project results to ensure
they are successful. For example, Oregon's Rogue River Basin Fish Access
Team, composed of local stakeholders, watershed councils, and state and
federal agencies (including BLM and the Forest Service), has established a
basinwide strategic plan to cooperatively prioritize fish passage barriers,
secure funding for projects, implement passage enhancement projects, and
monitor the success of projects. Specifically, to participate in the
program, a monitoring plan must be completed for each project before the
project begins. The monitoring plan must determine whether the project was
implemented as planned, was effective in solving fish passage problems, and
contributed to the expanding fish distribution across the Rogue River basin.
Potential techniques suggested to determine effectiveness include spawning
and snorkeling (underwater observation) surveys.

As their actions demonstrate, Oregon, Washington, and other entities
consider systematic monitoring to be an important tool to determine the most
effective methods for improving fish passage under various conditions. The
systematic monitoring allows the entities to incorporate this knowledge into
future restoration planning and implementation. Their varied approaches
reflect the range of methods available for monitoring- that is, monitoring
improvements to water flow at selected culverts of a specific design type,
verifying the actual presence of fish in a newly opened habitat, or
developing monitoring plans for specific projects. While each monitoring
approach requires a commitment of agency staff and funding to implement,
they all provide valuable information for targeting future expenditures on
culvert passage restoration methods that most

Page 20 GAO- 02- 136 Culvert Fish Passage

benefit fish. Oregon and Washington's monitoring efforts have helped them to
assess the success of various culvert passage restoration methods and
identified methods that require adjustments or further study to determine
their effectiveness. Without such systematic monitoring programs, neither
the Forest Service nor BLM can ensure that the federal moneys expended for
improving fish passage are actually achieving the intended purpose.

BLM and the Forest Service are faced with the daunting task of addressing a
large backlog of fish passage barrier culverts. Given the limited funding
available for fish passage projects and the various factors that affect the
agencies' ability to complete projects quickly, eliminating barrier culverts
will be a long, costly effort. While both agencies are already using culvert
assessment information to help them prioritize projects, that is just the
beginning of the barrier elimination process. Ultimately, the culvert
projects selected for implementation- whether retrofitting existing
culverts, replacing culverts, or removing culverts- must achieve the
objective of restoring fish passage. Systematic monitoring of completed
projects would provide the agencies with information to help them identify
which methods actually work best under various circumstances and evidence
that their expenditures have actually improved fish passage. Although
monitoring would divert funding and staff from the implementation of culvert
passage improvement projects, state monitoring programs have demonstrated
the value of monitoring to assess the effectiveness of barrier culvert
projects and to allow these entities to incorporate this knowledge into
future planning and implementation efforts.

To determine whether fish passage restoration projects are achieving their
intended purpose, we recommend that the Director of BLM and the Chief of the
Forest Service each develop guidance for systematically monitoring completed
barrier removal projects. This guidance should establish procedures that
will allow the agencies to cost- effectively measure and document
improvements to fish passage.

We provided the Department of the Interior and the Forest Service with a
draft of this report for comment prior to issuance. The agencies generally
agreed with the content of the report and concurred with our recommendation
for systematic monitoring so long as agency officials have the discretion to
determine the monitoring approaches and Conclusions

Recommendation for Executive Action

Agency Comments

Page 21 GAO- 02- 136 Culvert Fish Passage

methodologies that will most benefit them in planning and implementing
future fish passage projects. We recognize that the agencies will have to
exercise discretion in developing this guidance, but they need to ensure
that they implement a monitoring program that cost- effectively measures and
documents improvements to fish passage. The agencies also provided certain
technical clarifications, which we incorporated, as appropriate, in the
report. Copies of the agencies' comments are included as appendixes II and
III.

We conducted our review from March 2001 through October 2001 in accordance
with generally accepted government auditing standards. Details of our scope
and methodology are discussed in appendix IV.

We are sending copies of this report to the Director of the Bureau of Land
Management and the Chief of the Forest Service. We will also provide copies
to others on request.

If you or your staff have any question about this report, please call me at
(202) 512- 3841. Key contributors to this report are listed in appendix V.

Sincerely yours, Barry T. Hill Director, Natural Resources

and Environment

Appendix I: Barrier Culvert Information by Bureau of Land Management
District Office and National Forest

Page 22 GAO- 02- 136 Culvert Fish Passage

The Bureau of Land Management (BLM) and the Forest Service are assessing
culverts on their lands in Oregon and Washington to identify barriers to
fish passage. Neither agency has completed this effort, but each of the 10
district and 19 forest offices provided their assessment results as of
August 1, 2001. In addition, each district and forest office provided the
estimated total number of culverts on fish- bearing streams, an estimated
number of culverts not yet assessed that may be barriers, and an estimated
cost to restore fish passage through barrier culverts.

BLM districts reported that they have assessed 1,152 culverts for fish
passage and identified 414 barriers. In addition, the districts estimate
that 282 additional barrier culverts may exist. BLM estimates that the cost
to restore fish passage at all 696 of these barrier culverts could be about
$46 million, as shown in table 1. Appendix I: Barrier Culvert Information by

Bureau of Land Management District Office and National Forest

Bureau of Land Management

Appendix I: Barrier Culvert Information by Bureau of Land Management
District Office and National Forest

Page 23 GAO- 02- 136 Culvert Fish Passage

Table 1: BLM Fish Passage Barrier Culverts as of August 2001 Dollars in
thousands

BLM district Estimated

number of culverts on fish- bearing

streams Number of

culverts assessed for fish passage

Number of barrier culverts

identified Number of

barrier culverts estimated

Total number of barrier culverts

identified and estimated

Estimated cost to restore fish

passage at barrier culverts Oregon

Burns 2 2 0 00 0 Coos Bay 960 92 33 55 88 $2,561 Eugene 284 264 112 20 132
8,404 Lakeview 53 16 1 3 4 313 Medford a 167 154 57 10 67 7,931 Prineville 2
2 0 00 0 Roseburg a 879 500 150 30 180 19,800 Salem 466 117 60 164 224 7,425
Vale a 4 0 Unknown b Unknown b Unknown b Unknown b

Oregon total 2, 817 1,147 413 282 695 $46,434 Washington

Spokane 5 5 1 0113

Total all districts 2,822 1,152 414 282 696 $46,447

a Data reported by Medford, Roseburg, and Vale Districts do not include
culverts on streams bearing resident fish only. b Vale district did not
provide estimates as of August 1, 2001.

Source: BLM.

Forest Service national forest offices reported that they have assessed
2,986 culverts for fish passage and identified 2,160 barriers. In addition,
they estimate that an almost equal number, about 2,645, of additional
barrier culverts may exist. The Forest Service estimates that the cost to
restore fish passage at all 4,805 barrier culverts could be about $331
million, as shown in table 2. Forest Service

Appendix I: Barrier Culvert Information by Bureau of Land Management
District Office and National Forest

Page 24 GAO- 02- 136 Culvert Fish Passage

Table 2: Forest Service Fish Passage Barrier Culverts as of August 2001
Dollars in thousands

National forest Estimated

number of culverts on fish- bearing

streams Number of

culverts assessed for fish passage

Number of barrier culverts

identified Number of

barrier culverts estimated

Total number of barrier culverts

identified and estimated

Estimated cost to restore fish

passage at barrier culverts Oregon

Deschutes 200 180 134 0 134 $24,232 Fremont 600 177 138 262 400 10,000
Malheur 1,000 50 40 760 800 20,000 Mt. Hood 397 247 237 142 379 18,200
Ochoco 600 52 42 420 462 21,800 Rogue River 310 106 88 0 88 5, 560 Siskiyou
198 198 132 0 132 13,000 Siuslaw 540 491 270 0 270 25,427 Umatilla 392 200
180 0 180 33,000 Umpqua 236 107 96 116 212 Unknown a Wallowa- Whitman
Unknown a 0 0 Unknown a Unknown a Unknown a Willamette 991 323 310 116 426
77,000 Winema 120 0 0 80 80 2,000

Oregon total 5, 584 2,131 1,667 1,896 3,563 $250,219 Washington

Colville 250 100 0 50 50 Unknown a Gifford Pinchot 500 100 0 425 425 38,000
Mt. Baker Snoqualmie 250 130 56 67 123 10,701 Okanogan 150 77 74 66 140
8,000 Olympic 142 119 119 0 119 16,422 Wenatchee 517 329 244 141 385 7,700

Washington total 1, 809 855 493 749 1,242 $80,823 Total all forests 7, 393
2,986 2,160 2,645 4,805 $331,042

a According to the Forest Service, the Umpqua, Wallow- Whitman, and Colville
national forests did not provide estimates because their fish passage
assessments were not complete. Source: The Forest Service.

Appendix II: Comments From the Department of the Interior

Page 25 GAO- 02- 136 Culvert Fish Passage

Appendix II: Comments From the Department of the Interior

Appendix III: Comments From the Forest Service

Page 26 GAO- 02- 136 Culvert Fish Passage

Appendix III: Comments From the Forest Service

Appendix IV: Scope and Methodology Page 27 GAO- 02- 136 Culvert Fish Passage

To determine the number of culverts that may impede fish passage on BLM and
Forest Service lands in Oregon and Washington, we interviewed officials and
gathered documentation from BLM's Oregon State Office and the Forest
Service's Region 6 office, both located in Portland, Oregon. Specifically,
we gathered and analyzed information on the number and maintenance status of
culverts located in the 10 BLM districts under Oregon State Office
jurisdiction and the 19 national forests under Region 6 jurisdiction and the
costs and time frames associated with the repair of barrier culverts. We
conducted site visits at four BLM district offices in Oregon- Coos Bay,
Eugene, Medford, and Prineville- and at nine national forest offices-
Deschutes, Ochoco, Rogue River, Siskiyou, Siuslaw, Umatilla, and Williamette
in Oregon; and Gifford Pinchot and Olympic in Washington. We met with
district and forest office staff and collected information on their culvert
inventories and assessment and prioritization efforts and observed completed
and potential culvert restoration projects.

To identify the factors affecting the agencies' ability to restore passage
through culverts acting as barriers to fish, we interviewed BLM and Forest
Service headquarters officials, Oregon State Office and Region 6 officials,
and district and forest office staff and reviewed policies, procedures, and
practices for repairing, replacing, or removing barrier culverts. We
gathered and analyzed funding information for 141 anadromous fish passage
culvert projects completed in Oregon and Washington from fiscal year 1998
through July 2001, including the amount and source of funds expended for
each project. We analyzed detailed time line information for 56 of the 141
projects that included complete start and finish dates for the three main
phases of each project- federal and state clearances, design and
engineering, and construction. We interviewed agency officials and gathered
documentation to identify the factors that affect project time frames and to
determine how these factors limit the number of culvert projects that can be
completed annually.

To determine the results of the agencies' efforts to restore fish passage,
we gathered and analyzed information on the number of (1) culverts repaired,
replaced, or removed to improve anadromous fish passage and (2) miles of
habitat restored from fiscal year 1998 through August 1, 2001, by district
and forest offices under Oregon State Office and Region 6 jurisdiction. We
interviewed BLM and Forest Service headquarters, state and regional office,
and district and forest office officials and reviewed documentation to
determine whether regulations, policies, and procedures required systematic
monitoring of the effectiveness of the culvert restoration projects. To
identify state efforts to monitor the outcome of fish passage projects, we
interviewed Oregon and Washington state officials and Appendix IV: Scope and
Methodology

Appendix IV: Scope and Methodology Page 28 GAO- 02- 136 Culvert Fish Passage

reviewed regulations, policies, and procedures and monitoring reports
provided by the state agencies with fish passage restoration
responsibilities.

We conducted our work from March 2001 through October 2001 in accordance
with generally accepted government auditing standards.

Appendix V: GAO Contact and Staff Acknowledgments

Page 29 GAO- 02- 136 Culvert Fish Passage

Linda Harmon (202) 512- 8046 In addition to the above, Leo Acosta, Kathy
Colgrove- Stone, and Brad Dobbins made key contributions to this report.
Appendix V: GAO Contact and Staff

Acknowledgments GAO Contact Acknowledgments

(360052)

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