While
calling a recent report on the cost and benefits of removing the four
Lower Snake dams "unreliable," the Northwest Power and
Conservation Council's independent economic advisers say that
"perhaps" the region should again study the economic and
ecological impacts of removing the dams.
The
suggestion was included in the Independent Economic Advisory Board's
14-page review of "Revenue Stream: An Economic Analysis of the
Costs and Benefits of Removing the Four Dams on the
Lower Snake River
."
The
IEAB analysis is available at http://www.nwcouncil.org/library/ieab/ieab2007-1.htm
The
IEAB concludes that the Revenue Stream report "has a number of
deficiencies that raise serious questions about its acceptability as
an alternative to the Corps of Engineers Lower Snake EIS. Although it
may now be out of date and was not perfect, the Corps EIS has been
widely accepted as a credible analysis of the impacts of removing the
four lower Snake dams."
Revenue
Stream, released last November, was researched and prepared by staff
of Taxpayers for Common Sense, Save Our Wild Salmon, REP, PCFFA, the
Institute for Fisheries Research, Northwest Sportfishing Industry
Association, NW Energy Coalition and
American
Rivers
.
Revenue
Stream is available at http://www.wildsalmon.org/
The
report presents a comparison of the federal expenses of maintaining
and operating the dams versus the costs of removing the dams and
replacing their benefits. It
claimed that removing the four lower
Snake River
dams would bring $5 billion in savings to taxpayers and increased
economic benefits from new and restored industries.
The
Council asked the IEAB to review the report.
While
pointing out what it perceived as several shortcomings in the report,
the IEAB said, "Perhaps it is time for the region to consider
doing a follow-on study of the four lower Snake dams that would
address some of the weaknesses of the Corps study, and that would
update the study to reflect the many changes in the regional economy,
regional transportation systems, power generation and transmission,
the successes and failures of current recovery efforts, and the
improved models of fish biology, dam passage and ocean survival now
available."
The
Revenue Stream report estimates that the cost of hydropower
replacement if the dams were removed is substantially below the cost
estimates reported in the Army Corps of Engineers Lower Snake
Environmental Impact Statement in 2000.
"This
is crucial," says the IEAB, "because the cost of replacement
power is potentially a large continuing cost if the four lower
Snake River
dams were removed."
In
looking at the details of the report, the Council's economic advisers
say:
--
Based upon review of the Corps of Engineers' cost estimate, the
Revenue Stream report underestimates hydropower replacement costs by
enough to invalidate their main result that the region could save
money by removing the dams.
-- The
report is not a peer reviewed analysis, the work was not conducted by
an open public process, and many of the sources that the report relied
on came from reports that were also not products of an open, public,
peer reviewed process. Consequently, the IEAB does not have a solid
basis to either accept or reject many of the cost and benefit
estimates in the Revenue Stream report.
-- The
report does not discount future benefits and costs of dam removal.
Discounting recognizes that people give greatest weight to immediate
costs and benefits. Because some large costs of dam removal occur
immediately, while other costs and benefits occur slowly over many
years, lack of discounting could have a significant impact on the
conclusions of the report.
-- The
report estimates the cost of maintaining the salmon program in the
Columbia basin with and without the four lower Snake River dams, and
then poses the difference between these two costs as a cost saving.
The cost estimates reflect a diverse mix of Federal agency budgets and
estimated additional salmon recovery costs. It is not clear that the
agency budgets reflect full or accurate cost estimates, or that they
rely on a common definition of costs.
-- The
report argues that dam removal will have substantial additional
benefits due to the recovered fishery. The reported recreational
fishery benefits rely heavily on a study by Don Reading (2004), which
the IEAB reviewed in December 2005. We concluded that
Reading
had made a number of methodological errors which seriously biased his
benefit estimates upward. The non-fishery recreational benefits are
derived from a study by John Loomis (1999) which the IEAB reviewed
during our overall review of the Corps' EIS in 2001. We had
significant concerns about some of Loomis' results as well, and the
numbers actually used in the final Corps EIS differed substantially
from those presented in the original Loomis study. Hence, the Revenue
Stream's reported benefits from salmon recovery in the
Snake River
appear unreliable.
-- The
Corps EIS set a high standard as an open, public and peer reviewed
analysis that has not been matched by any other study of dam removal,
and is certainly not matched by the Revenue Stream report. Because
Revenue Stream uses numbers from reports that do not result from an
open peer reviewed process, it is difficult to assess the validity of
these studies, whether they use appropriate methodology, rely on good
data, or use compatible assumptions.
-- The
Revenue Stream report itself reflects some inappropriate methodology
choices. SOS's choice to not address the likely distribution of costs
and benefits over time or to discount future costs and benefits is a
major failing of the report. In other cases, the Revenue Stream report
does not clearly document the methodology they used to derive their
estimates, making it impossible for us to replicate or critique their
numbers.
"While
the IEAB concludes that there are enough problems with the Revenue
Stream report that it cannot be viewed as a credible alternative to
the Corps Lower Snake EIS analysis of the impacts of removing the four
lower Snake dams, we want to emphasize that the EIS is not necessarily
the last word on the topic," said the economists.
In
suggesting the region consider doing a "follow-on study" of
dam breaching, the economic advisers noted that, "When the IEAB
served as formal reviewer of the Corps EIS, one of our conclusions was
the region should "… invest in improved estimates of economic
benefits from dam breaching to reduce the range of uncertainty and to
improve confidence in them …" At the time the IEAB had a number
of criticisms and suggestions for how the analysis could and should be
improved.
"Because
there are a number of weaknesses to the Corps study, because some of
the assumptions and methodologies used by the Corps are controversial,
and because the world, especially the power cost world, is a much
different place than it was in the late 1990s when much of the Corps
analysis was done, it is easy to see why people continue to question
whether the Corps EIS is the final word on the topic."
In
reaction to the IEAB, the sponsors of Revenue Stream applauded the
suggestion that the region should invest in further study of removing
the four lower
Snake River
dams.
"We
applaud the IEAB's call for additional economic study of the removal
of the four lower
Snake River
dams," said Nicole Cordan, policy and legal director with Save
Our Wild Salmon.
"We're
grateful that the IEAB has focused attention on the flaws and
weaknesses of the Corps study. We clearly can't make informed,
long-term decisions on how to best restore and recover Snake River
salmon and the communities that depend upon them without
comprehensive, current and unbiased information," said Liz
Hamilton, executive director of the Northwest Sportfishing Industry
Association, one of the sponsors of the report. "We look forward
to working with Congress to ensure that Revenue Stream is a catalyst
for constructive debate, as it was intended to be, and urge them to
move forward on the studies that IEAB suggests."