Energy Regulation:

Opportunities for Strengthening Hydropower Cumulative Impact Assessments

RCED-88-82: Published: Mar 10, 1988. Publicly Released: Mar 24, 1988.


Victor S. Rezendes
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In response to a congressional request, GAO examined the Federal Energy Regulatory Commission's (FERC) responsibilities under the Federal Power Act for assessing the cumulative impact of hydroelectric power projects on natural resources, specifically: (1) FERC plans for using the River Basin Environmental Impact Statement Procedure (EIS) as an alternative to the Cluster Impact Assessment Procedure (CIAP); and (2) deficiencies in FERC impact assessment procedures and whether the development of comprehensive plans can address these deficiencies.

GAO found that: (1) FERC designed CIAP to ensure early and extensive state and federal resource agency involvement in assessments through several public meetings and workshops, whereas EIS required only one public meeting; (2) although FERC was not legally required to formally notify the public of its decision to use EIS as it did before using CIAP, its failure to do so could appear to be a withdrawal from its earlier efforts to encourage public involvement in the assessments; (3) interested parties felt that FERC had inadequate data on the extent to which other land and water uses could adversely affect resources to carry out a reasoned evaluation; and (4) although Congress amended the act to require FERC to consider the extent to which hydroelectric projects were consistent with federal and state comprehensive plans, FERC had no further plans for implementing the amendment other than issuing requirements for comprehensive development.

Status Legend:

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  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: The Chairman, FERC, should formally announce FERC plans for using CIAP, EIS, or some other procedure to carry out future assessments and provide interested parties with an opportunity to comment on such plans.

    Agency Affected: Federal Energy Regulatory Commission

    Status: Closed - Implemented

    Comments: FERC plans no action to formally announce plans for using any particular procedures for assessing cumulative impacts in river basins prior to the review. FERC maintains that environmental assessments (EA) and environmental impact statements (EIS) will have a section on cumulative impacts. In addition, the manner in which cumulative impacts were addressed will be explained in the EA and EIS.

    Recommendation: The Chairman, FERC, should direct FERC staff to take an active role in implementing section 10(a)(2) of the Federal Power Act by encouraging and facilitating the development of comprehensive plans prepared by states and federal agencies. Such action could involve, among other things: (1) providing timely information to states and agencies on whether plans that they submitted meet the requirements of section 10(a)(2) and how they can be modified to meet the requirements; and (2) holding workshops with state and federal agencies on how comprehensive plans can be prepared.

    Agency Affected: Federal Energy Regulatory Commission

    Status: Closed - Implemented

    Comments: FERC issued an order which directed FERC staff to: (1) advise filers of river basin plans as to whether they meet the requirements for comprehensive plans and, if not, why not; and (2) make itself available to discuss comprehensive planning with state and federal personnel.

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