This is the accessible text file for GAO report number GAO-02-803 
entitled 'Oregon Inlet Jetty Project: Environmental and Economic 
Concerns Need to Be Resolved' which was released on October 04, 2002.



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Report to Congressional Requesters:



September 2002:



OREGON INLET JETTY PROJECT:



Environmental and Economic Concerns Still Need to Be Resolved:



GAO-02-803:



Results in Brief:



Background:



Corps Generally Has Not Maintained the Oregon Inlet Ocean Bar 

Navigation Channel at Its Authorized Depth:



Corps’ Economic Analysis for the Proposed Oregon Inlet Jetty Project 

Has Several Limitations That Undermine Its 

Usefulness:



Performance of Similar Jetty Projects Has Been Mixed:



Corps Applied Lessons Learned from Similar Jetty Projects in Designing 

the Oregon Inlet Jetty Project, but Information on Fish Larvae 

Migration Is Not Available:



Commerce and Interior Remain Concerned That the Oregon Inlet Jetty 

Project Will Harm the Environment:



Conclusions:



Recommendations for Executive Action:



Agency Comments and Our Evaluation:



Scope and Methodology:



Appendixes:



Appendix I: The Corps’ Process for Developing Water Resource Projects:



Appendix II: Chronology of Significant Events for the Oregon Inlet 
Jetty

Project, 1950 through 2002:



Appendix III: Approved Oregon Inlet Dredging Operations that Were Not 

Performed:



Appendix IV: Review of the Corps’ Economic Analysis of the Proposed 
Oregon

Inlet Jetty Project:



Appendix V: Comparison of the Proposed Oregon Inlet Jetty Projects:



Appendix VI: Comments from the Department of the Army:



Appendix VII: Comments from the Department of the Interior:



Appendix VIII: Comments from the Department of Commerce:



Appendix IX: GAO Contact and Staff Acknowledgements:



Tables:



Table 1: Estimated Average Number of Annual Trips Made by Commercial 

Fishing Vessels through Oregon Inlet, for the Periods 1984-1986 and 

1999-2001:



Table 2: Performance of the Eight Jetty Projects Incorporating Weirs:



Table 3: Approved Oregon Inlet Dredging Operations That Were Not 

Performed for Some of the Fiscal Years from 1990 through 2001:



Table 4: Comparison of Estimated Annual Benefits and Costs of 

Alternatives for Achieving a 20-Foot-Deep Navigation Channel for Oregon 

Inlet:



Table 5: Summary of Information in U.S. Coast Guard Investigation Files 

on Vessel Losses at Oregon Inlet, 1961 through 1986:



Table 6: Listing of Vessel Losses and Deaths Attributed to Conditions 
at 

Oregon Inlet, June 28, 1986, through November 27, 2001:



Table 7: Listing of Vessel Damages Attributed to Conditions at Oregon 

Inlet between June 28, 1986, and September 30, 2001:



Table 8: Key Characteristics of the Proposed Oregon Inlet Jetty Project 

and Similar Completed Jetty Projects:



Figures:



Figure 1: Oregon Inlet’s Location Along the North Carolina and Virginia 

Coastlines:



Figure 2: Aerial View of Oregon Inlet on September 18, 2001:



Figure 3: The Corps’ Proposed Design for the Oregon Inlet Jetty Project 

as of September 2001:



Figure 4: Funding Requested, Approved, and Expended for Dredging the 

Oregon Inlet Ocean Bar Navigation Channel, Fiscal Years 1990 through 

2001:



Figure 5: The Weir in the North Jetty at Masonboro Inlet, North 
Carolina:



Figure 6: The Dual Jetty Project at Colorado River Inlet, Texas:



Abbreviations:



CEQ Council on Environmental Quality:



DOI Department of the Interior:



EIS Environmental Impact Statement:



FWS Fish and Wildlife Service:



GAO General Accounting Office:



GDM General Design Memorandum:



NMFS National Marine Fisheries Service:



NOAA National Oceanographic and Atmospheric Administration:



NPS National Park Service:



OMB Office of Management and Budget:



September 30, 2002:



The Honorable Max Baucus

United States Senate:



The Honorable John Edwards

United States Senate:



Oregon Inlet is the primary route to the ocean for hundreds of 

commercial and recreational fishing vessels operating in the Outer 

Banks region of North Carolina. However, the inlet experiences more 

high winds, strong tides, and shifting sand than any other inlet on the 

Atlantic coast of the United States. This high-energy environment often 

creates sand bars and large breaking waves at the inlet’s entrance to 

the ocean, commonly known as the ocean bar. These conditions, 

especially when combined with the severe storms that frequent the area, 

can swamp a boat or run it aground, imperiling both life and property. 

According to the U.S. Army Corps of Engineers and U.S. Coast Guard 

data, over the 40-year period 1961 through 2001, hazardous conditions 

in the inlet were a factor in 25 deaths and the loss of 22 vessels.



In 1950, in an attempt to improve navigation at Oregon Inlet, the 

Congress authorized the Corps to dredge a channel in the inlet--called 

the ocean bar navigation channel--to a depth of 14 feet.[Footnote 1] 

From 1960 through 2001, the Corps’ Wilmington District Office, which is 

responsible for maintaining the ocean bar navigation channel at Oregon 

Inlet, spent about $108 million dredging this channel.[Footnote 2] 

Additional efforts to improve the safety of the channel are conducted 

by the U.S. Coast Guard, which is responsible for, among other things, 

maintaining the navigation aids that help guide vessels through the 

inlet. In 1970, in an effort to stabilize Oregon Inlet and in response 

to local concerns that a deeper channel was needed to accommodate 

fishing vessels and commercial traffic, the Congress authorized the 

construction of dual rock jetties and a 20-foot-deep ocean bar 

navigation channel for Oregon Inlet.[Footnote 3] Since this 

authorization, the Corps has completed and updated numerous economic 

and environmental analyses to determine if construction of the project 

is justified. In the latest update of its economic analysis, completed 

in 2001, the Corps estimated that the project would yield annualized 

net benefits of about $7.2 million over 50 years, largely from savings 

that were projected to be attained from reduced operating costs for 

commercial fishing vessels and increased activity by recreational 

boaters. Annualized costs were estimated at about $4.5 million. As a 

result, annual net benefits (benefits minus costs) for the proposed 

jetty project were estimated at $2.7 million. However, although the 

Corps and others have completed many studies over the last 30 years, 

the Congress has never appropriated funds specifically to construct the 

project. During this period there have been major disagreements among 

federal, state, and local governmental entities, including the 

Departments of Commerce and Interior, as well as among environmental, 

fishing, and recreational groups, about whether the project is 

economically justified and whether it would harm the environment by, 

among other things, increasing beach erosion and restricting the 

migration of fish larvae from the ocean to the sounds inside the inlet, 

where the larvae develop into fish.



You asked us to review several issues related to the Corps’ Oregon 

Inlet jetty project. Specifically, we agreed to (1) assess federal 

efforts to maintain the ocean bar navigation channel in Oregon Inlet, 

(2) assess the extent to which the Corps’ 2001 economic analysis of the 

jetty project is useful for decision making, (3) provide information on 

the performance of similar jetty projects, that is, those constructed 

with dual jetties and a low section called a weir,[Footnote 4] (4) 

determine whether the Corps’ Wilmington District Office applied lessons 

learned from similar jetty projects in its design of the Oregon Inlet 

jetty project, and (5) identify and discuss concerns raised by the 

Departments of Commerce and Interior about development of the jetty 

project.



Results in Brief:



During the past 19 years, the Corps has had difficulty maintaining the 

ocean bar navigation channel at Oregon Inlet at its authorized 14-foot 

depth. Specifically, from 1983 through 1994, the Corps spent on average 

about $4.1 million per year dredging the channel, but was only able to 

maintain the authorized 14-foot depth on average about 23 percent of 

the time. After 1994, the Corps spent an average of about $2 million 

per year, but the percentage of time the channel depth was maintained 

at its authorized depth declined to about 15 percent. According to a 

2001 engineering and design document issued by the Corps, its dredging 

efforts at Oregon Inlet have not provided a safe and navigable ocean 

bar navigation channel, and hazardous navigation conditions at the 

inlet will continue to cause the loss of human life and injuries as 

well as vessel losses and damages. Wilmington District Office officials 

said that the high-energy environment and storms associated with Oregon 

Inlet have often thwarted the Corps’ plans and depleted its funding for 

dredging the inlet. In addition, the district has sometimes had to 

reallocate funds that were earmarked for dredging Oregon Inlet to other 

district projects in response to emergencies caused by the frequency 

and magnitude of area storms. Further, because of the Corps’ limited 

dredging and the inlets high-energy environment, the Coast Guard has 

been unable to maintain and properly position its navigation buoys for 

the channel, which further increases the risk of damage to vessels and 

injuries to people.



The Corps’ most recent economic analysis of the proposed Oregon Inlet 

jetty project, issued in 2001, has several limitations, and as a 

result, does not provide a reliable basis for deciding whether to 

proceed with the project. For example, the Corps relied on outdated 

data to estimate the benefits to large commercial fishing vessels 

(trawlers). More recent data indicates that trawlers currently use the 

inlet far less than the Corps estimated in its economic analysis. On 

the other hand, the Corps did not analyze the potential benefits the 

proposed jetty project may provide to smaller commercial fishing 

vessels. However, because these smaller vessels have shallower drafts 

than trawlers, the extent to which they might benefit from the jetty 

project is uncertain. The analysis also did not account for the 

economic value of the lives that might be saved by the jetty project, 

which could understate benefits; it also overstated the cost of the 

current dredging program, and it used an overly optimistic assumption 

concerning future dredging needs that would tend to understate the cost 

of the jetty project. We did not assess the net effects of all the 

limitations we found with the economic analysis because obtaining the 

necessary data would require an inordinate amount of time and expense. 

These limitations, however, can result in either overstated or 

understated estimated benefits and costs.



Of the eight completed jetty projects constructed similarly to the 

proposed Oregon Inlet jetty project, two are generally performing as 

planned. Of the six other similar projects, three have required more 

dredging and higher maintenance costs than expected, and two have had 

their weirs closed--one because the responsible Corps’ District did not 

accurately determine the direction of sand movement and constructed the 

weir on the wrong jetty, and the other because of problems with the 

instability of the channel and with boaters using the weir as a 

shortcut, creating a safety hazard. According to the Corps, the 

problems at these five projects stemmed from inaccurate information on 

sand movement when the projects were initially designed. At the sixth 

project, more sand has accumulated in the navigation channel than 

expected, but this occurred because the Corps did not fully construct 

the area designed to collect sand deposits. As a result, according to 

the Corps, the navigation channel has been available at its authorized 

depth only about 20 percent of the time.



In designing the proposed Oregon Inlet jetty project, the Corps’ 

Wilmington District Office applied lessons learned from the 

construction of similar jetty projects and from internal Corps 

guidance. For example, the Wilmington District staff stated that from 

its construction and management of the Masonboro Inlet jetty project in 

North Carolina--one of two similar jetty projects that are generally 

performing as planned--it learned about the need for dual jetties, the 

proper length of a weir, and the effect of erosion on jetties. District 

staff stated that from internal Corps guidance they learned about, 

among other things, the importance of having accurate information on 

sand movement in designing the proposed Oregon Inlet jetty project. 

Nonetheless, the Corps stated that because each jetty project is 

designed for a unique environment, lessons learned from similar 

projects would not predict all aspects of the performance of the Oregon 

Inlet project. For example, the Corps incorporated a weir into the 

design of Oregon Inlet’s northern jetty to allow fish larvae that 

migrate near the ocean shoreline to travel over the jetty, through the 

inlet, and into the sound. None of the eight similar jetty projects 

with weirs were designed to provide for fish larvae migration.



Both the Department of Commerce and the Department of the Interior 

support the goal of providing a safe navigation channel through Oregon 

Inlet for commercial and recreational fishing vessels. However, both 

departments support a dredging-only approach to achieve that goal in an 

environmentally acceptable manner. Commerce, which manages marine 

resources, including fisheries, and Interior, which manages the 

federally owned land upon which the jetties would be built, have raised 

several environmental concerns about the construction of the Oregon 

Inlet jetty project. For example, Commerce believes that constructing 

the project will cause unacceptable harm to commercial and recreational 

fishery resources by limiting the ability of fish larvae to reach 

habitat necessary for their development. Commerce is also concerned 

that the jetties will significantly alter sand movement in the vicinity 

of Oregon Inlet and damage beaches, dunes, beds of submerged aquatic 

vegetation, salt marshes, shallow water habitats, and other aquatic 

sites and resources. Interior believes that the jetties will increase 

beach erosion, especially on the south side of the inlet, and that the 

project’s sand bypassing system could harm coastline habitat and 

wildlife by depositing large quantities of sand onto Interior’s land 

each year without allowing sufficient time for recovery of the 

ecosystem. For these and other reasons, Interior has maintained that 

constructing the jetties is not consistent with the missions of its 

National Park Service (NPS), which manages the Cape Hatteras National 

Seashore to the north and south of Oregon Inlet, and Fish and Wildlife 

Service (FWS), which manages the Pea Island National Wildlife Refuge to 

the south of the inlet, and has denied the Corps the permits needed to 

build the jetties on Interior’s lands. To address the concerns of 

Commerce and Interior, the Corps revised its original jetty design to 

shorten the length of the jetties and incorporate a weir, which it 

believes will mitigate the concerns about fish larvae migration. The 

weir is also intended to facilitate the collection of sand, which the 

Corps plans to transport to adjacent beaches to address erosion. 

However, both Commerce and Interior have stated these actions will not 

achieve the desired results. In October 2001, because Commerce, 

Interior, and the Corps were unable to reach agreement on these issues, 

Commerce referred the matter to the Council on Environmental Quality--

an entity established by the National Environmental Policy Act to 

resolve interagency disagreements concerning major federal actions that 

might cause negative environmental effects. Interior has also asked the 

council to consider its concerns. The Corps does not believe it should 

spend additional public resources to develop the project until it has 

assurances that the environmental issues will be favorably resolved.



Lacking resolution of environmental concerns from the council and 

construction permits from Interior, we agree with the Corps that it 

should not pursue further development of the Oregon Inlet jetty 

project. If, however, both of these issues are favorably resolved, we 

are recommending that in order to have a reliable economic basis for 

deciding whether to proceed with the project, the Secretary of the Army 

direct the Corps to prepare a new and comprehensive economic analysis 

of the project’s costs and benefits that would provide the more current 

and complete information needed to justify construction of the project. 

In commenting on a draft of this report, the Departments of the Army, 

Commerce, and Interior generally agreed with our findings and 

recommendations. The Department of Transportation did not comment on 

our overall findings and recommendations, but offered specific 

technical comments.



Background:



The Corps’ mission is both military and civilian and involves providing 

quality, responsive engineering services to the nation. The Corps’ 

involvement in civil engineering projects, such as the proposed Oregon 

Inlet jetty project, comes under the auspices of the Director of Civil 

Works and falls into four broad categories: water infrastructure, 

environmental management and restoration, response to natural or man-

made disasters, and engineering and technical services. The Corps is 

organized geographically into eight divisions and 41 districts that are 

responsible for implementing individual projects. The Corps’ 

Wilmington, North Carolina, District Office, part of the South Atlantic 

Division, is responsible for maintaining a safe and navigable waterway 

at Oregon Inlet. Appendix I provides a description of the Corps’ 

process for developing a water resource project.



Oregon Inlet provides the only access to the Atlantic Ocean from inland 

waters located between Rudee Inlet in Virginia Beach, Virginia, about 

85 miles to the north of Oregon Inlet, and Hatteras Inlet in Hatteras, 

North Carolina, about 45 miles to the south. Oregon Inlet is located in 

the Outer Banks, a string of barrier islands along the coast of North 

Carolina. According to a study of Outer Banks sediment and inlet 

dynamics, these barrier islands and their migrating inlets consist of 

dynamic sedimentary deposits, which, left to nature, constantly move 

and change under the influence of waves, currents, and the change in 

sea level. Overall, these islands are slowly moving toward the mainland 

at an average rate of about 4.5 feet per year. In addition, along the 

ocean side of the Outer Banks, the sands flow predominantly toward the 

south. For this reason, the islands and Oregon Inlet naturally move in 

a southerly direction. At least a dozen separate inlets have naturally 

opened and closed along the Outer Banks’ coastline over the three 

centuries that preceded the formation of Oregon Inlet.[Footnote 5] 

Currently, there are three inlets along the Outer Banks: Oregon Inlet, 

Hatteras Inlet, and Ocracoke Inlet. Figure 1 shows the location of 

Oregon Inlet and its surrounding features.



Figure 1: Oregon Inlet’s Location Along the North Carolina and Virginia 

Coastlines:



[See PDF for image]



Source: Corps’ Wilmington District Office.



[End of Figure]



Oregon Inlet experiences a combination of more high winds, strong 

tides, storms, and shifting sand than any other inlet along the 

Atlantic coast of the United States. These high-energy conditions often 

create hazards for vessels attempting to pass through the inlet to or 

from the ocean. Vessels making this passage use the ocean bar 

navigation channel, which extends from a point about 1,500 feet inside 

the Herbert C. Bonner Bridge (commonly known as the Bonner Bridge) to a 

point in the ocean called the ocean bar, about 10,000 feet outside the 

bridge.[Footnote 6] At the ocean bar, sand naturally accumulates and 

waves break on the surface because of the shallow water. Nonetheless, 

hundreds of vessels pass through the inlet each year. In 1999 through 

2001, according to North Carolina Division of Marine Fisheries data, on 

average, about 311 commercial fishing vessels used Oregon Inlet a total 

of about 3,900 times each year to access the ocean. During this period, 

commercial fishing vessels using the inlet landed more than 18 million 

pounds of fish at seafood dealers that operate inside the inlet.



The North Carolina Department of Transportation is currently evaluating 

preliminary plans for constructing a bridge that would replace the 

Bonner Bridge. The new bridge would be located farther west than the 

current bridge and may make landfall several miles farther south than 

the current bridge, possibly bypassing the Pea Island National Wildlife 

Refuge. According to a state engineer, the proposed elevated portion of 

the new bridge would be 5,000 feet long, which would allow the natural 

migration of Oregon Inlet to the south and also permit the navigation 

channel to be moved as conditions dictate. The proposed completion date 

for the new bridge is 2010. Figure 2 provides an aerial view of Oregon 

Inlet.



Figure 2: Aerial View of Oregon Inlet on September 18, 2001:



[See PDF for image]



Source: Adapted from a Corps’ Wilmington District Office photo mosaic.



[End of Figure]



The safety and navigability of Oregon Inlet has been the subject of a 

series of engineering, economic, and environmental studies by the 

Corps’ Wilmington District Office. In the 1960s, local officials and 

other interested parties told the Corps that the original 14-foot 

navigation channel authorized by the Congress in 1950 was not adequate 

because it was not deep enough to accommodate larger vessels and 

existing dredging was not sufficient to provide a stable channel at its 

authorized dimensions. Subsequently, the House and Senate Public Works 

Committees asked the Corps to study whether any modifications of the 

Oregon Inlet project were advisable. Based on this work, the Corps made 

recommendations that led the Congress to authorize the dual rock 

jetties and a 20-foot navigation channel for Oregon Inlet in 1970. The 

authorization increased the depth of the ocean bar navigation channel 

from 14 feet to 20 feet, in part to accommodate the use of larger, 

deep-draft commercial fishing vessels that were expected to use the 

inlet in the future.[Footnote 7]



Between the 1970 authorization and September 30, 2001, the Corps’ 

Wilmington District Office has spent about $10 million (current 

dollars) designing the project and studying whether it was economically 

and environmentally sound before construction could begin. These 

studies have included at least four updates of the district’s economic 

analyses and four environmental impact statements, as well as various 

redesigns of the project. According to the Corps, it has also made a 

substantial effort to coordinate its efforts with other interested 

agencies. For example, the Corps stated that it has worked with the 

Department of Commerce’s National Marine Fisheries Service and the 

North Carolina Division of Marine Fisheries to develop data on fish 

catch and associated use of the inlet by commercial fishing vessels. 

The Corps also participated in a joint task force with the Department 

of the Interior in 1991 to determine the effect of the jetties and the 

project’s proposed sand bypass system on the adjacent shoreline. In 

response to concerns raised by the task force, the Corps revised the 

proposed project by, among other things, reducing the length of the 

jetties and incorporating a weir to facilitate sand bypass and fish 

larvae migration. On September 21, 2001, the Corps issued Supplement 

No. 2 General Design Memorandum (GDM) and Final Supplement III 

Environmental Impact Statement (EIS), which state that the dual jetties 

and the 20-foot navigation channel are economically justified and 

environmentally acceptable. The Corps document also found that current 

dredging efforts at Oregon Inlet have not provided a safe and navigable 

ocean bar navigation channel and concluded that hazardous navigation 

conditions at the inlet will continue to cause injuries and the loss of 

human life as well as vessel damages and losses. However, as of 

September 2002, the Congress had not appropriated funds to construct 

the jetty project.



Despite the many studies and modifications to the project that the 

Corps has made over the last 30 years, the Department of Commerce, the 

Department of the Interior, various environmental groups such as the 

Biodiversity Legal Foundation, and other interested parties such as the 

North Carolina Saltwater Fishing Club, do not believe their concerns 

have been adequately addressed by the Corps’ analysis, and they have 

continued to oppose the project. In general, these entities contend 

that the Corps’ economic analysis is unsound and that the jetty project 

will cause significant beach erosion and impede migration of fish 

larvae to habitat in the sound, potentially leading to a significant 

reduction in the overall fish supply. Further, these entities state 

that other factors, such as navigational errors, may contribute to the 

potential for loss of life at the inlet, a risk that would not be 

reduced by construction of the jetties. Commerce and Interior also 

anticipate that the project will have adverse impacts to designated 

Essential Fish Habitat in the immediate area of Oregon Inlet that is 

required by fish for spawning, breeding, feeding, or growing to 

maturity.[Footnote 8] However, the jetty project is strongly supported 

by the state of North Carolina and the local commercial and 

recreational fishing industry, which contend that the project is needed 

to ensure safe passage for vessels through the inlet, particularly 

larger, deep-draft commercial fishing vessels.



Although the U.S. Coast Guard has not taken an official position on the 

project, it is directly involved in issues concerning Oregon Inlet. The 

Coast Guard is responsible for maintaining the buoys and markers used 

to guide vessels through the ocean bar navigation channel and other 

channels in the sounds on the inside of the inlet. Coast Guard units 

located in Hatteras, North Carolina, and Portsmouth, Virginia, maintain 

the navigation aids at Oregon Inlet. In addition, the Coast Guard 

Station Oregon Inlet is responsible for, among other things, search and 

rescue and boating safety in coastal waters and sounds from the 

Virginia-North Carolina border to approximately Hatteras Island, North 

Carolina.



Figure 3 shows the Corps’ current design for the proposed jetty 

project. The project includes construction of dual rock jetties about 

3,000 feet apart. The north jetty would be approximately 10,000 feet 

long; the south jetty would extend about 3,500 feet beyond the Pea 

Island terminal groin, for a total length of about 6,600 feet. The 

terminal groin is a rock structure that was completed in 1991 to 

protect the southern end of the Bonner Bridge by stabilizing and 

restoring the tip of Pea Island. At the time, the erosion of Pea Island 

was threatening the southern end of the Bonner Bridge. The project also 

incorporates a weir in the north jetty that is designed to serve two 

basic purposes: 1) to facilitate sand bypassing from a deposition basin 

to adjacent beaches and 2) to aid fish larvae migration from the ocean 

past the jetties, through the inlet, and into the sound. A detailed 

chronology of significant events related to the development of the 

Oregon Inlet jetty project is provided in appendix II.



Figure 3: The Corps’ Proposed Design for the Oregon Inlet Jetty Project 

as of September 2001:



[See PDF for image]



Source: Adapted from Supplement No. 2 General Design Memorandum, Manteo 

(Shallowbag) Bay, North Carolina, Corps’ Wilmington District, September 

2001. The map is based on May 26, 1996, aerial photography.



[End of Figure]



Corps Generally Has Not Maintained the Oregon Inlet Ocean Bar 

Navigation Channel at Its Authorized Depth:



The Corps has had difficulty maintaining Oregon Inlet’s ocean bar 

navigation channel at its authorized depth of 14 feet. According to 

officials in the Corps Wilmington District Office, from August 1983 

through March 1994 the 14-foot depth was maintained about 23 percent of 

the time.[Footnote 9] During this period, the Corps spent an average of 

about $4.1 million annually to dredge the channel. In recent years, 

however, expenditures on dredging the channel have declined to an 

average of about $2 million annually, and the Corps has been able to 

maintain the channel’s authorized 14-foot depth only about 15 percent 

of the time. According to Wilmington District officials, the district 

has not been able to maintain the channel’s authorized depth because 

the inlets’ high-energy environment constantly moves sand back into the 

navigation channel and because funding limitations restrict the amount 

of dredging that can be performed. Officials said that the district 

does not get all of the funds it requests and often has to reallocate 

funds that are earmarked for dredging Oregon Inlet to respond to 

emergencies elsewhere in the district. The Corps’ limited dredging and 

the high-energy environment of the inlet also affect the Coast Guard’s 

ability to adequately maintain buoys that are supposed to mark the 

ocean bar navigation channel for vessels using Oregon Inlet. In fact, 

navigation charts for Oregon Inlet do not display the location of 

navigation aids, such as buoys, because they are frequently moved by 

the Coast Guard due to continuously shifting sand and by severe storms. 

These conditions increase the risk of danger to vessels and injuries to 

people.



The Inlet’s Environment and the Corps Limited Resources Have Hindered 

Dredging of the Ocean Bar Navigation Channel:



Oregon Inlet experiences more high winds, strong tides, and shifting 

sand than any other inlet on the Atlantic coast of the United States. 

This high-energy environment is magnified by a high incidence of 

storms, particularly those from the northeast (called nor’easters) 

during the fall and winter months. For example, between 1990 and 1998, 

the Oregon Inlet area was affected by more than 100 significant storms, 

some of them hurricanes. Storms heighten ocean waves and increase sand 

movement in the inlet. Based on Corps studies, an average of about 2.1 

million cubic yards of sand move in and around Oregon Inlet each 

year.[Footnote 10] In comparison, annual sand movement for the two 

jettied inlets closest to the Oregon Inlet is about 471,000 cubic yards 

for Rudee Inlet in Virginia and about 700,000 cubic yards for Masonboro 

Inlet in North Carolina.



In addition to causing massive sand movement each year, district 

officials noted that the frequency and severity of storms at Oregon 

Inlet significantly affect the district’s budget and dredging plans. 

Specifically, according to district officials, their budget and 

dredging plans are prepared 18 to 24 months in advance of the actual 

work. However, predicting storms that far into the future is 

impossible, and, for this reason, yearly budgets and dredging plans 

often differ significantly from actual needs. As a result, the district 

has often had to reallocate funds among its projects to meet immediate 

needs and is not able to perform all planned activities for Oregon 

Inlet, such as dredging. Figure 4 illustrates fluctuations in funding 

requested, approved, and expended to dredge the ocean bar navigation 

channel.



Figure 4: Funding Requested, Approved, and Expended for Dredging the 

Oregon Inlet Ocean Bar Navigation Channel, Fiscal Years 1990 through 

2001:



[See PDF for image]



Note: Amounts are expressed in 1997 constant dollars.



Source: GAO analysis of data provided by the Corps of Engineers’ 

Wilmington District Office.



[End of Figure]



As shown in figure 4, in some years from 1990 through 2001, the 

district did not spend all of the funds that had been approved for 

dredging the ocean bar navigation channel; in other years, it spent 

more. For example, for 6 of the 12 years, the district received 

approval to spend about $22.5 million, but spent about $10.8 million, 

or about $11.7 million less than the approved amount. In those years 

the district reallocated the $11.7 million budgeted for dredging the 

Oregon Inlet ocean bar navigation channel to address other higher-

priority emergency needs in the district. For example, in fiscal year 

1999, reallocated funds were used to remove sand bars and debris that 

were causing hazardous navigation conditions in the Atlantic 

Intracoastal Waterway. These hazards had unexpectedly accumulated after 

a severe storm. Conversely, in the other 6 years, the district spent 

more funds than were initially approved for dredging the ocean bar 

navigation channel. Specifically, the district spent about $25.4 

million, or about $6.5 million more than the $18.9 million that had 

been initially approved during those years. For example, in fiscal year 

1991, the district received approval for about $4.7 million to dredge 

the channel, but spent about $7.0 million, which it obtained by 

reallocating funds from other projects within the district. District 

Office officials explained that in many of these years the district 

experienced several hurricanes and other storms that necessitated 

redirecting funds from some projects to perform emergency work on other 

projects.



Wilmington District Office officials said that another reason they 

often need to reallocate funds is because they do not receive all of 

the funding that they request. Although district officials noted that 

getting requested funding would not ensure that the ocean bar 

navigation channel was always maintained at the authorized depth of 14 

feet, it would ensure that the authorized depth was maintained more 

often and would also reduce the amount of funds that the district has 

to reallocate among its projects during emergencies. For example, 

between fiscal years 1990 and 2001, the district requested about $55 

million for dredging the ocean bar channel and obtained approval to 

spend about $41 million, or 75 percent of what it requested.



For the most part, as shown in figure 4, the district has significantly 

reduced the amount of funds it has requested and spent on dredging the 

ocean bar navigation channel over the last few years. During this 

period there has also been a notable decline in the Corps’ ability to 

maintain the channel’s 14-foot depth. Specifically, between August 1983 

and March 1994, when the Corps spent an average of about $4.1 million 

per year dredging the channel, it was able to maintain the authorized 

14-foot depth about 23 percent of the time. However, between March 1994 

and October 2001, the Corps has only maintained the channel at its 

authorized depth about 15 percent of the time. District officials 

explained that in the late 1980s and early 1990s, the district needed 

to dredge a large volume of sand that had accumulated in the navigation 

channel around the Bonner Bridge. Due to the location of this sand and 

the Corps’ desire to place it on Pea Island to prevent erosion, the 

district used a pipeline dredge to remove the sand. Generally, a 

pipeline dredge is significantly more expensive to operate than other 

types of dredges because of the cost to set up the pipeline that 

transports the removed sand to a new location. By the end of 1995, the 

Corps had successfully removed the sand affecting the navigation 

channel and deposited it on Pea Island. As a result, according to 

district officials, the district reduced its funding requests for 1996 

through 2001 because it did not expect to use an expensive pipeline 

dredge to remove that much sand again during that period. However, 

during that time, there was a reduction in the Corps’ ability to 

maintain the ocean bar navigation channel at its authorized depth.



District officials also said that their budget requests have never 

included the total amount of funds needed to maintain the ocean bar 

navigation channel at its authorized depth 100 percent of the time. 

District officials stated that in the past they could not justify 

spending the time and money needed to prepare a request for such an 

amount because there was little likelihood that the amount would be 

received. However, district officials stated that in their fiscal year 

2003 budget request they included a request for $10.9 million, which is 

an amount they believe is needed to maintain the channel at 14 feet 100 

percent of the time.



Oregon Inlet’s High-Energy Environment and the Corps’ Limited Dredging 

Have Also Reduced the Coast Guard’s Ability to Properly Mark the Ocean 

Bar Navigation Channel:



The Coast Guard is responsible for maintaining the buoys that mark the 

Oregon Inlet channel. Coast Guard officials said that they have 

difficulty maintaining the buoys marking the location of deep water in 

the ocean bar navigation channel because the high-energy conditions in 

the inlet cause large amounts of sand to move in and out of the 

channel. This sand movement often changes the location of deep water 

and, when combined with the Corps’ limited dredging, results in sand 

accumulation around the buoys. According to the Coast Guard, when sand 

accumulates on the channel side of the buoys to a depth that approaches 

the draft of a buoy tender, it becomes difficult and sometimes 

impossible to relocate the buoys to mark deeper water. For example, on 

October 30, 2001, the Coast Guard asked the Corps to provide a vessel 

to relocate 6 of the 13 buoys that were located in the inlet at that 

time. The Corps vessel could operate in shallower water and had the 

lift capability to relocate the buoys.



In addition, as part of an ongoing waterway analysis and management 

program, the Fifth Coast Guard District reported on November 14, 2001, 

that the buoys in Oregon Inlet are always moving due to storms. The 

report states that after every large storm, several buoys at Oregon 

Inlet are either damaged, moved, or both, and it is difficult to 

maintain and keep these buoys in the proper location because of limited 

Coast Guard resources. According to the commanding officer of one of 

the Coast Guard vessels that services Oregon Inlet, there is no easy 

way to provide a reliable navigational aid system in Oregon Inlet. The 

commanding officer said that over the years buoys have been added and 

removed in attempts to properly mark the navigation channel, but the 

location of deep water changes regularly. The commanding officer also 

said that the north side of the channel is almost impossible to mark 

reliably because sand regularly shifts into and out of the channel as 

Bodie Island moves south, creating a constant navigational hazard.



The buoys that mark the deep water of the ocean bar navigation channel 

are frequently moved and are therefore not charted. According to Coast 

Guard officials, vessel operators who are not aware of the shifting 

sand conditions are susceptible to running their vessels aground. As a 

result, the Coast Guard suggests that vessel operators call its Coast 

Guard Station Oregon Inlet to obtain the most recent navigation data 

before attempting to traverse the ocean bar navigation channel.



Corps’ Economic Analysis for the Proposed Oregon Inlet Jetty Project 

Has Several Limitations That Undermine Its Usefulness:



We identified several limitations in the Corps’ economic analysis that 

undermine its usefulness for assessing whether the Corps’ preferred 

alternative of a dual jetty project with a 20-foot navigation channel 

is economically justified. For example, the analysis overstated the 

benefits to large commercial fishing vessels (trawlers) based on their 

current fishing activities, but did not analyze the potential benefits 

the proposed jetty project may provide to smaller commercial fishing 

vessels. However, because these smaller vessels have shallower drafts 

than trawlers, the extent to which they might benefit from the jetty 

project is uncertain. The analysis also did not account for the 

economic value of the lives that might be saved by the jetty project, 

which could result in understated benefits; it also overstated the cost 

of the current dredging program and used an overly optimistic 

assumption concerning future dredging needs that would tend to 

understate the cost of the jetty project. (See app. IV for more details 

on these and other limitations to the economic analysis.) We did not 

assess the effects of all these limitations on the net benefits of the 

Corps’ economic analysis because obtaining the necessary data would 

require an inordinate amount of time and expense. As a result, we 

cannot say what the net effect of addressing all the limitations would 

be on the net benefits and the benefit-cost ratio of the Corps’ 

preferred jetty project alternative.



Corps Estimate of Benefits to Commercial Fishing Vessels Is Based on 

Outdated and Incomplete Data:



The Corps estimated that the recommended jetty project would generate 

about $2 million in annualized benefits by reducing the operating costs 

of commercial fishing vessels. The Corps anticipates that the 

recommended project would reduce these costs by alleviating hazardous 

conditions in Oregon Inlet that sometimes force the vessels, especially 

trawlers, to detour to more distant inlets or ports. The Corps based 

its benefit estimate on the savings that would occur if the number of 

detoured trips and their related operating costs were reduced. In 

estimating operating cost savings, the Corps included savings in 

“fixed” operating costs, which it defined as including, among other 

things, depreciation charges on the vessel, insurance, interest on 

loans, and taxes.



In calculating the estimated benefit, the Corps relied on data provided 

in a 1987 consultant’s report that studied the number of trips taken by 

trawlers during the mid-1980s.[Footnote 11] However, these data do not 

reflect the fewer trips taken by trawlers in recent years. Further, the 

Corps overstated the operating costs savings that trawlers would likely 

achieve by including all the fixed-costs portions of their hourly 

operating costs. The appropriate measure of savings is variable costs 

(costs that vary with the length of fishing trips) that would be saved 

by reducing the number of detoured trips. This would include the cost 

of such items as fuel and oil but not such items as taxes and 

insurance, which likely would remain the same whether or not the jetty 

project is built.



In addition, by relying on the consultant’s study, the Corps excluded 

from its analysis the trips taken by smaller (shorter than 55 feet) 

commercial fishing vessels. These vessels were excluded because the 

consultant’s study did not assess the effect of inlet conditions on the 

operating costs of smaller fishing vessels.



As shown in table 1, according to data from the North Carolina Division 

of Marine Fisheries, about 97 trawlers averaged 679 trips through 

Oregon Inlet from 1999 through 2001.[Footnote 12] By contrast, the 

consultant’s 1987 study found that about 234 trawlers averaged about 

4,500 trips through Oregon Inlet from 1984 through 1986. Both the 

state’s data and the 1987 consultant’s study suggest that the number of 

smaller commercial fishing vessels using the inlet has significantly 

increased since the mid-1980s. State officials indicated, however, that 

because the state and the consultant used different methods to collect 

the data--the state’s data are based on a census of commercial fish 

landings and the consultant’s data were based primarily on interviews 

of selected seafood dealers and trawler captains--the state’s data and 

the consultant’s data may not be fully comparable.[Footnote 13] We 

attempted to verify the data used by the consultant, but the Corps no 

longer has the supporting documentation for the study. Nonetheless, any 

assessment of the effect of the proposed jetty project on commercial 

fishing activities should be based on current commercial fishing trip 

data, which the state has collected through its trip ticket program. As 

a result, the Corps’ reliance on the consultant’s 1987 study calls into 

question the usefulness of the Corps’ estimate of the benefits of the 

jetty project to commercial fishing vessels.



Table 1: Estimated Average Number of Annual Trips Made by Commercial 

Fishing Vessels through Oregon Inlet, for the Periods 1984-1986 and 

1999-2001:



Time period: 1994-1986[C]; Trawlers[A]: Number: 234; Trawlers[A]: 

Annual trips: 4,498; Trawlers[A]: Number of trips detoured: 1,896; 

Trawlers[A]: Landings (million lbs): 15; Smaller vessels[B]: Number: 25 

- 30; Smaller vessels[B]: Annual trips: [D]; Smaller vessels[B]: Number 

of trips detoured: [D]; Smaller vessels[B]: Landings (million lbs): 

2.8.



Time period: 1999-2001[E]; Trawlers[A]: Number: 97; Trawlers[A]: Annual 

trips: 679; Trawlers[A]: Number of trips detoured: [D]; Trawlers[A]: 

Landings (million lbs): 8.6; Smaller vessels[B]: Number: 214; Smaller 

vessels[B]: Annual trips: 3,249; Smaller vessels[B]: Number of trips 

detoured: [D]; Smaller vessels[B]: Landings (million lbs): 9.8.



[A] Vessels that are at least 55 feet long :



[B] Vessels that are shorter than 55 feet:



[C] Source: 1987 Kearney/Centaur study:



[D] Not available:



[E] Source: North Carolina Division of Marine Fisheries. :



[End of table]



According to an official with the North Carolina Division of Marine 

Fisheries, the change in trawler trips likely reflects changes in 

federal and state limits on the fish harvest. For example, in 1992, 

several management measures---including a moratorium on the issuance of 

new licenses for fishing and a 13-inch limit on the size of fish that 

can be harvested---were implemented to reduce over-fishing of flounder, 

a fish species traditionally caught by trawlers operating out of Oregon 

Inlet. During the mid-1980s, before these resource management measures 

were imposed, about 7.7 million pounds of flounder were landed annually 

through Oregon Inlet. By contrast, from 1999 through 2001, about 2.2 

million pounds were landed annually through Oregon Inlet. According to 

Commerce, the size of the commercial fleet has declined due to a vessel 

reduction program implemented by the South Atlantic Fishery Management 

Council.



Corps officials said that they relied on the methodology of the 

consultant’s 1987 report because they considered it “independent,” and 

that even though the trips by smaller vessels were not explicitly 

included in the analysis, the difficulties experienced by the trawlers 

were indicative of all commercial fishing vessels. In addition, the 

officials said that the recent trawler trip activity reflects, at least 

in part, a decrease in the reliability of the channel due to the lack 

of adequate operation and maintenance funds. They also said that the 

deeper channel provided by the proposed jetty project might attract 

other trawler operators to relocate to the Oregon Inlet area. However, 

the Corps’ assumption about the total hours delayed by inlet conditions 

is based on trawler trips, and it is not appropriate to apply the 

potential savings to smaller vessels without corroborating evidence 

that they, too, are affected in the same way as trawlers. In addition, 

while the decrease in trawler traffic may reflect a number of factors, 

including fishery management measures and a decrease in the reliability 

of the 14-foot channel, the Corps’ analysis is not useful for assessing 

these factors because it relies on data from the mid-1980s that do not 

reflect current commercial fishing vessel traffic, the fisheries 

management measures that have been put in place since the mid-1980s, or 

changes in the reliability of the channel.



To illustrate how using the more recent trawler trip data would affect 

the Corps commercial benefits estimate, we adjusted the Corps’ analysis 

to account for the number of fishing trips that trawlers have recently 

taken. We also adjusted the Corps analysis to exclude certain fixed 

vessel costs. Based on these adjustments, we found that the annualized 

commercial fishing benefits would be reduced by about 90 percent, from 

about $2 million to $194,000. However, accounting for the effect of the 

proposed jetty project on smaller fishing vessels could increase this 

adjusted estimate of the benefits to commercial fishing vessels. 

Because these smaller vessels have a shallower draft than trawlers, 

they may not be as affected by the sand accumulations in the ocean bar 

navigation channel that can be hazardous to trawlers. For this reason, 

the extent to which smaller vessels might benefit from the jetty 

project is uncertain. We could not assess the effect of the proposed 

jetty project on the smaller commercial fishing vessels because there 

are insufficient data on the extent to which these vessels are delayed 

by conditions in the inlet.



Corps’ Estimate of Benefits Did Not Incorporate the Economic Value of 

Accidental Deaths That Might be Prevented by the Proposed Jetty 

Project:



The Corps did not incorporate the economic value of the lives that 

might be saved by the jetty project into its net benefit estimates. 

Consequently, to the extent that the jetty project reduces accidental 

deaths, accounting for the economic value of the lives saved could 

increase the benefits estimate (all other factors being the same). 

Federal guidance on water project analysis does not require that the 

economic value of the lives that might be saved by a project be 

included in the estimate of net benefits. Nonetheless, it is standard 

economic practice to incorporate this economic value into the benefits 

estimate so that decision makers can assess the full range of benefits 

that might be generated by a federal investment or regulation. For 

example, in assessing the benefits of safety improvements that reduce 

the risk of premature death, the Department of Transportation uses an 

estimate of the “value of a statistical life,” which is $3 million per 

averted death (2002 dollars).[Footnote 14]



Corps officials said that their policy is to quantify the number of 

lives that might be saved by a project but not to estimate their 

economic value, because procedures for estimating the economic value of 

a life are not included in federal guidelines for analyzing water 

projects, and the Corps prefers that the project be assessed without 

the influence of the economic benefits attributable to lives saved. The 

officials said that they do consider the potential life-saving issues 

along with other factors, such as the benefit-cost ratio, in deciding 

whether to recommend that a project be implemented. Nonetheless, an 

alternative approach that does not require valuation but explicitly 

considers lives saved can be useful for assessing whether projects that 

have negative net benefits (that is, “net costs” when costs exceed 

benefits or the benefit-cost ratio is less than 1) may still be worth 

implementing. Under this approach, the net costs (exclusive of lives 

saved) are divided by the number of lives saved, and the estimate can 

be compared with other federal investments to ascertain whether the 

proposed project’s estimate of net cost per life saved is comparable to 

that achieved by other federal investments or regulations.



The Corps estimated 14 accidental deaths would be prevented by the 

project. However, the Corps’ analysis assumes that all prior vessel 

accidents that included deaths would be prevented by the jetty project 

and does not clearly control for factors that would be present with or 

without the jetty project. For example, Corps officials told us that 

under some weather conditions the inlet would be hazardous even with 

the recommended 20-foot channel and dual jetties in place. Further, the 

Corps did not control for factors that include changes in type of 

vessel traffic, operator experience, and vessel safety technology, all 

of which will continue to play a role in the number of accidents and 

deaths in the inlet with or without the jetty project. In commenting on 

a draft of this report, the Departments of Commerce and Interior noted 

that the economic costs of the potential effect of the jetties on 

accidental deaths, vessel damage, and personal injuries resulting from 

the construction of the jetties are not incorporated in the analysis.



Corps’ Estimate of Project Cost Does Not Include More Recent Data on 

Lower Expenditures and Uses an Overly Optimistic Assumption on Future 

Dredging Needs:



Using costs for dredging that the Wilmington District incurred from 

fiscal years 1983 through 1996, the Corps’ economic analysis estimated 

that the annualized cost of the current 14-foot dredging program is 

about $8.4 million. The $8.4 million includes $6.5 million in average 

annual operation and maintenance (O&M) expenditures and about $1.9 

million in other costs.[Footnote 15] In contrast, the Corps estimated 

that the proposed jetty project would cost $12.9 million ($6.1 million 

in O&M costs and $6.8 million in other costs).[Footnote 16] To 

determine the incremental or “net cost” that would be associated with 

implementing the jetty project alternative, the Corps appropriately 

subtracted the annualized cost of the current dredging program ($8.4 

million) from the annualized cost of the proposed jetty project ($12.9 

million). Based on this analysis, the Corps determined that 

implementing the jetty project alternative would cost $4.5 million more 

annually than the Corps spends on the current dredging program.



The Corps’ $6.5 million O&M cost estimate for the current dredging 

program is based on expenditures from fiscal years 1983 through 1996. 

However, for fiscal years 1997 through 2001, the Corps spent only about 

$3.9 million per year on dredging. By updating the Corps’ expenditure 

data through fiscal year 2001, we found that the Corps’ annualized 

estimate of the current dredging program would be reduced from $8.4 

million to $7.4 million.[Footnote 17] Consequently, the net costs of 

the jetty project would increase from $4.5 to about $5.5 million. Corps 

officials agreed that dredging expenditures have declined to about $3.9 

million annually in recent years for the reasons cited earlier in this 

report.



In addition, in estimating the cost of the jetty project, the Corps 

excluded $945,000 that it spent from 1983 through 2001 dredging in 

Pamlico Sound, which is not part of the ocean bar navigation channel. 

The Corps excluded this cost because it assumed that dredging this area 

in Pamlico Sound would not be required as part of the recommended jetty 

project. Corps officials said that the source of the sand in this area 

is the ocean and, based on their best engineering judgment, this area 

will naturally flush itself after the jetties are built; therefore, 

this dredging cost will no longer be incurred.



However, several coastal engineers and geologists familiar with the 

Corps’ proposed jetty project told us that the jetties would not 

eliminate dredging this area of the sound. In general, they believe 

that whether the source of the sand is the ocean or rivers that drain 

into the sound, the man-made channel will fill back in with the sand 

adjacent to it and require dredging. As a result, there is uncertainty 

about whether the Corps will continue to dredge this area. Nonetheless, 

if the Corps does have to dredge this area, then the cost of the jetty 

project would be higher than the Corps estimated in its economic 

analysis (all other factors being the same).



Performance of Similar Jetty Projects Has Been Mixed:



Corps district officials identified eight jetty projects located on the 

Atlantic Ocean and Gulf of Mexico coastlines that are similar to the 

proposed Oregon Inlet project in that they incorporate dual jetties and 

a weir. According to data provided by the Corps, two of these jetty 

projects, both south of Oregon Inlet on the Atlantic coast, are 

generally performing as planned, and six others are not. Two projects 

are considered by the Corps to be performing as planned because the 

Corps has not had to dredge the project’s navigation channel more than 

originally predicted. For the six jetty projects that are not 

performing as planned, one has a navigation channel that is frequently 

not at its authorized depth, three have required more dredging and 

higher dredging costs than expected,[Footnote 18] and two have had 

their weirs closed. According to Corps officials responsible for these 

six jetties, a key factor in why these jetties have not performed as 

planned was inaccurate information on sand movement when the projects 

were initially designed. According to the Corps and other experts, good 

estimates of sand movement are essential to successfully designing a 

weir jetty project that will facilitate the bypass of sand to adjacent 

beaches while ensuring the availability of a navigation channel with 

minimum dredging costs. Table 2 summarizes the performance of the eight 

dual jetty projects that incorporate weirs.



Table 2: Performance of the Eight Jetty Projects Incorporating Weirs:



Jetty project: Murrells Inlet, SC; Location: Atlantic Ocean Coast; More 

dredging than planned: [Empty]; Weir closed: [Empty]; Poor channel 

availability: [Empty]; Generally performing as planned: X.



Jetty project: Colorado River, TX; Location: Gulf of Mexico Coast; More 

dredging than planned: X; Weir closed: [Empty]; Poor channel 

availability: X; Generally performing as planned: [Empty].



Jetty project: Ponce DeLeon, FL; Location: Atlantic Ocean Coast; More 

dredging than planned: [Empty]; Weir closed: X; Poor channel 

availability: [Empty]; Generally performing as planned: [Empty].



Jetty project: St. Lucie, FL; Location: Atlantic Ocean Coast; More 

dredging than planned: [Empty]; Weir closed: [Empty]; Poor channel 

availability: X; Generally performing as planned: [Empty].



Jetty project: Perdido Pass, AL; Location: Gulf of Mexico Coast; More 

dredging than planned: X; Weir closed: [Empty]; Poor channel 

availability: [Empty]; Generally performing as planned: [Empty].



Jetty project: East Pass, FL; Location: Gulf of Mexico Coast; More 

dredging than planned: [Empty]; Weir closed: X; Poor channel 

availability: [Empty]; Generally performing as planned: [Empty].



Jetty project: Rudee, VA; Location: Atlantic Ocean Coast; More dredging 

than planned: X; Weir closed: [Empty]; Poor channel availability: 

[Empty]; Generally performing as planned: [Empty].



Jetty project: Masonboro, NC; Location: Atlantic Ocean Coast; More 

dredging than planned: [Empty]; Weir closed: [Empty]; Poor channel 

availability: [Empty]; Generally performing as planned: X.



Source: GAO analysis of Corps data.



[End of table]



Two Projects Are Currently Performing As Planned:



According to the Corps’ Charleston District staff, which is responsible 

for the Murrells Inlet jetty project, the project has performed as 

expected because maintenance dredging of the navigation channel, which 

was planned for every 3 years, has only been needed once since the 

jetty project was built. That dredging occurred in 1988, and additional 

dredging is planned for 2002. District staff said the channel through 

the inlet has been kept open primarily by the flushing action of 

currents flowing through the jetties and has had lower maintenance 

costs than expected.



The Corps’ Wilmington District staff, which is responsible for the 

jetty project at the Masonboro Inlet, said the project is considered to 

be performing as planned currently because they have only had to dredge 

the project’s sand deposition basin every 3 or 4 years, which is less 

than the planned frequency of once a year. However, the Masonboro Inlet 

project was originally constructed in 1966 as a single jetty with a 

weir on the north side of the inlet, which did not perform effectively. 

The 1,000-foot weir was the first structure of its type to be 

constructed in the United States. Tides and current undermined the 

jetty because the inlet’s channel continued to migrate. As a result, 

the Corps repaired the first jetty and, in 1980, constructed a second 

jetty on the south side of the inlet, which stabilized the locations of 

the channel and the sand deposition basin. After the south jetty was 

built, however, sand that the Corps predicted would accumulate in the 

deposition basin instead began accumulating at the south end of 

Wrightsville Beach. This sand eventually formed a spit and required 

vessels entering the inlet to make a sharp turn in strong crosscurrents 

in order to stay in the navigation channel.[Footnote 19] However, by 

using the sand spit as an extended deposition area, the Wilmington 

District has only had to dredge the deposition area every 3 or 4 years. 

According to district officials, this is also enough dredging to keep 

the spit from further encroaching into the navigation channel, which is 

otherwise kept open by the currents and tides passing between the 

jetties. (See fig. 5 for photographs of the Masonboro Inlet weir.):



Figure 5: The Weir in the North Jetty at Masonboro Inlet, North 

Carolina:



[See PDF for image]



The picture on the left shows that high tide covers the weir, while the 

picture at the right shows that the weir is exposed at low tide. The 

weir’s elevation is 2.16 feet above mean low water measured at the 

inlet.



Source: GAO.



[End of Figure]



Six Projects Are Not Performing As Planned:



Project managers provided the following specific details about four 

jetty projects, including the jetty project that has incurred expected 

dredging costs, but whose navigation channel is frequently not 

maintained at its authorized depth, and the performance of the three 

jetty projects that have incurred higher than expected dredging costs.



* At St. Lucie Inlet, Florida, the Jacksonville District was performing 

the amount of dredging expected, but more sand accumulated in the 

navigation channel than was anticipated because the Corps did not 

complete construction of the deposition basin that was to collect the 

sand that passes over the weir. As a result, since the jetty project 

was constructed, the Corps has been able to maintain the navigation 

channel at its authorized depth of 16 feet only about 20 percent of the 

time. Plans are under way to complete construction of the deposition 

basin. The Jacksonville District believes that construction of the 

deposition basin, as well as other modifications to the jetty project, 

will help maintain the channel at its authorized depth 100 percent of 

the time.



* For the jetty project at Rudee Inlet built by the City of Virginia 

Beach, Virginia, officials said they expected to dredge 100,000 cubic 

yards of material annually. However, according to the city staff, 

actual dredging at the inlet has averaged 300,000 cubic yards annually 

because more sand than expected has flowed over the weir. Although the 

project has required more dredging than planned, a consultant for the 

city of Virginia Beach states that even with higher dredging costs, the 

expenditures are justified, because the inlet provides many 

recreational and commercial benefits.



* For the jetty project at Perdido Pass (inlet) in Alabama, the Corps’ 

Mobile District said that this project was designed for the Corps to 

dredge about 100,000 cubic yards of material annually; however, to keep 

the navigation channel at its authorized depth, the Corps has actually 

had to dredge about 361,000 cubic yards of material every 2 to 3 years.



* For the jetty project at the Colorado River Inlet in Texas, the 

Corps’ Galveston District expected to dredge about 536,000 cubic yards 

of sand every 2 years, or an average of 268,000 cubic yards annually. 

However, the actual amount of material dredged annually was about 

680,000 cubic yards, or about two and a half times what was planned. 

The need for this additional dredging occurred because the amount of 

sand flowing over the weir has been greater than expected, and the sand 

has tended to be deposited in the navigation channel rather than in the 

project’s deposition basin. (See fig. 5 below for a photo of this 

project.) Despite the extra dredging, the Corps’ Galveston District 

reported that the channel was available at its authorized depth only 

about 30 percent of the time. The need for more dredging than planned 

has caused the responsible Corps districts to incur additional 

maintenance costs. For example, the Galveston District has spent about 

$1.9 million annually for dredging the Colorado Inlet, more than four 

times the $425,000 that it planned to spend for annual dredging when 

the project was designed.



Figure 6: The Dual Jetty Project at Colorado River Inlet, Texas:



[See PDF for image]



The east jetty is on the right and contains the weir, which is 

paralleled by a fishing 

walkway. More sand than expected has passed over the weir and been 

deposited 

in the channel, as indicated by the narrowing of the river in this 

view.



Source: The Corps of Engineers’ Galveston District.



[End of Figure]



The Corps districts had to close the weirs for two of the jetty 

projects because they did not work as planned. Specifically, in 1985, 

at the East Pass, Florida, jetty project, the Mobile District decided 

to fill in the weir that was built in 1969 because the east side of the 

weir was eroding, and only a limited amount of sand was accumulating in 

the deposition basin. The problem arose because the predominant 

direction of the sand flow was opposite to what the Corps expected when 

the jetty project was designed. In 1985, after the Corps determined 

that the weir was constructed on the wrong jetty, it closed the weir. 

In another case, in 1984, the Corps’ Jacksonville District closed the 

weir at Ponce DeLeon Inlet, Florida, because the weir was believed to 

be causing erosion problems north of the inlet and instability in the 

inlet’s navigation channel. In addition, the weir caused safety 

concerns because boaters were attempting to cross over it to go to and 

from the ocean, instead of using the navigation channel. Appendix VI 

provides a comparison of the proposed Oregon Inlet jetty project to 

similar completed jetty projects.



Corps Applied Lessons Learned from Similar Jetty Projects in Designing 

the Oregon Inlet Jetty Project, but Information on Fish Larvae 

Migration Is Not Available:



Corps officials at the Wilmington District Office stated that in 

designing the Oregon Inlet jetty project, they applied lessons learned 

from the construction and management of similar jetty projects and from 

internal Corps guidance. Specifically, from experiences gained in 

designing, constructing and managing the Masonboro Inlet jetty project 

in North Carolina, Wilmington District officials stated that they 

learned:



* how to construct dual jetties to avoid problems with channel 

migration and to ensure that sand accumulates in the intended area,



* how to determine the proper length of the weir section, and:



* how to design jetties to prevent the structures from being undermined 

or weakened by erosion.



In addition to the lessons learned from this actual experience, 

Wilmington District officials stated that they used the Corps’ internal 

guidance on the design of jetty projects, which is based on lessons 

learned from other Corps projects. Specifically, this guidance 

emphasizes the importance of having accurate information on sand 

movement in designing a sand bypass system such as the one proposed for 

the Oregon Inlet jetty project. Following this guidance, the district 

used 20 years of data on sand movement in designing the sand bypass 

system for the Oregon Inlet jetty project.



Although the Corps used these lessons in designing the Oregon Inlet 

jetty project, there are still some uncertainties about whether the 

project will perform as planned. For example, although the Wilmington 

District used measurements of sand movement taken over the 20-year 

period, these data were obtained from 1956 through 1975 and are now 

more than 25 years old. More recent data on sand movement at Oregon 

Inlet are available for the period from 1976 through 2001; however, the 

Wilmington District has not updated its estimates because it believes 

that the new data would not change its existing estimates 

significantly. Because this updated data was not included in the 

economic analysis, it is uncertain what effect the more recent data 

would have on the Corps’ estimate of sand movement and dredging costs.



Another issue related to sand movement is the accuracy of the models 

used to make these estimates. Although the Corps used some of the best 

models available to estimate sand movement at Oregon Inlet, Corps 

officials acknowledged that these models are imprecise and generate 

results that could vary by as much as plus or minus 40 percent. This 

variation could affect the actual dredging and sand bypassing costs 

that would be incurred if the jetty project were built. To provide for 

this uncertainty, the Corps included additional dredging costs of about 

$288,000 annually in its economic analysis.



Another uncertainty relates to the impact of the proposed jetty project 

on the migration of fish larvae. Although none of the similar jetty 

projects with weirs were designed to facilitate fish larvae migration, 

the Corps believes that incorporating a weir into the Oregon Inlet 

jetty project will minimize the impact of the project on fish larvae. 

However, fisheries experts stated that there are no definitive data on 

how any jetty projects, with or without weirs, affect fish larvae 

migration.



Commerce and Interior Remain Concerned That the Oregon Inlet Jetty 

Project Will Harm the Environment:



Both the Department of Commerce and the Department of the Interior 

support the goal of providing a safe navigation channel through the 

Oregon Inlet for commercial and recreational fishing vessels. However, 

both departments support a dredging-only approach to achieve that goal 

in an environmentally acceptable manner and have raised several 

concerns about the Corps’ plans for stabilizing the inlet with jetties.



Commerce believes that the Corps’ environmental impact statement (EIS) 

for the project is flawed and that the preferred jetty alternative 

would cause unacceptable environmental harm to commercial and 

recreational fishery resources. Specifically, Commerce’s National 

Oceanic and Atmospheric Administration (NOAA), which is mandated to 

manage the nation’s living marine resources, believes that the Corps’ 

jetty project would eliminate or degrade significant areas of highly 

productive fishery habitat, thereby reducing fishery resources. 

According to NOAA, such habitat is vital for the development of many 

marine species, including shrimp, red drum, summer flounder, and 

bluefish, which are found in the Outer Banks. NOAA maintains that the 

jetties would alter the near-shore currents and reduce successful 

movement of fish larvae, small juvenile fish, and invertebrates, which 

are dependent on the currents to carry them into the sheltered 

estuaries of the Albemarle and northern Pamlico Sounds. According to 

NOAA, this is a particular concern for the economically valuable fish 

that spawn offshore in the fall and winter, such as flounder. While 

raising these concerns, NOAA recognizes that current data on fish 

larvae migration are not sufficient to quantify the impact that the 

proposed Oregon Inlet jetties would have on fish larvae migration. 

However, NOAA points out that there are no studies or data available on 

how weirs or jetties in general affect fish larvae migration, and it 

believes that constructing the jetties without this information is an 

unacceptable risk. Commerce also noted that without construction of the 

jetties, the safety record of vessels using Oregon Inlet has increased 

dramatically over the past 20 years.



Interior, which manages the federally owned land on which the proposed 

jetties would be constructed, has long opposed the project.[Footnote 

20] Interior’s National Park Service manages the Cape Hatteras National 

Seashore, where the proposed northern jetty would be built, and 

Interior’s Fish and Wildlife Service manages the Pea Island National 

Wildlife Refuge, where the proposed southern jetty would be 

built.[Footnote 21] Since the Corps first prepared an EIS for the 

project in 1979, both of these agencies have consistently raised 

concerns that the proposed jetties will adversely affect fish and 

wildlife habitat. In general, Interior has expressed the following 

concerns:



* The jetties will increase beach erosion. Interior stated that if the 

jetties are built, erosion and accretion patterns will be modified both 

north and south of the inlet, which in turn will increase overwash of 

the islands, especially during storms. This overwash will harm valuable 

wildlife habitat, as well as plants and vegetation that provide food 

for waterfowl and other migratory birds. Interior also stated that this 

erosion could exceed the Corps’ estimates and create a further real 

threat of additional construction on Interior land to save the jetties. 

Finally, Interior stated that the increased erosion would also threaten 

the infrastructure at and adjacent to Oregon Inlet, including state 

highway 12. Interior noted that the design of the Bonner Bridge 

requires the inlet’s navigation channel to remain fixed under a single 

span of the bridge. However, the proposed replacement bridge currently 

being considered by the state has a proposed elevated portion 5,000 

feet long that would allow the navigation channel to be moved as 

conditions dictate. According to Interior, this would eliminate the 

need for the jetties and an existing rock structure (known as the 

terminal groin) that was built to protect the southern end of the 

Bonner Bridge. Interior stated that under the terms of the permit it 

granted to the state to construct the terminal groin, the structure 

would probably be removed once the new bridge is constructed.



* The sand bypass system that was designed to mitigate the adverse 

effects of beach erosion will permanently alter existing shoreline 

habitat and disrupt shorebird nesting, resting, and feeding areas on a 

temporary, seasonal, or permanent basis. For example, Interior states 

that each sand bypass will harm invertebrate animals (small clams, 

worms, and crabs) that inhabit the shoreline and provide a valuable 

food source for shorebirds and fish. Interior stated that over the 

years frequent sand bypassing of large volumes might permanently 

eliminate these food sources and produce severe long-term adverse 

impacts on breeding, migrating, and over-wintering shorebirds. Among 

these birds are the Great Lakes piping plover population, which is 

federally listed as endangered, and the Atlantic/Canada coast piping 

plover population, which is federally listed as threatened. There is 

also concern that the perpetual placements of incompatible sands will 

diminish successful nesting by the threatened loggerhead sea turtle and 

green sea turtle. Nesting takes place south of the inlet on the refuge, 

which is an area expected to experience the greatest erosion due to the 

jetties and therefore would require the most sand placement. In 

addition, the trapping and bypassing of the sand will not allow the 

sand to naturally migrate into Pamlico Sound, which could have and 

adverse effect on intertidal marshes, sandflats, mudflats, and 

submerged aquatic vegetation, all of which are important fish and 

wildlife habitat.



* The weir will not function as planned. Interior stated that the Corps 

has not provided interested agencies with its analysis, studies, or 

other data that would support how the weir will perform and notes that 

the proposed weir design has not been field-tested. Interior also 

expressed concern that the Corps’ planning has not adequately 

considered the impact of the Dare County beach replenishment project on 

the weir. Specifically, according to Interior, the project will take, 

on average, over one million cubic yards of sand from the ocean and 

place it on the beaches north of Oregon Inlet each year. The movement 

of this additional sand from the northern beaches southward toward 

Oregon Inlet would increase the likelihood of the weir becoming 

landlocked, which in turn would allow sand to pass around the north 

jetty and into the ocean bar navigation channel. This would increase 

the possibility that considerable supplemental dredging would be 

required and/or that the Corps may ultimately be required to build 

longer jetties, as originally planned. These actions would 

significantly increase the cost of the jetty project. Interior also 

said that if the weir were to become landlocked, it would nullify the 

expected benefit of facilitating the migration of fish larvae.



* Construction of the jetties will diminish much of the public’s 

recreational use of the Bodie Island spit, which, according to 

Interior, is contrary to one of the legislative purposes of the Cape 

Hatteras National Seashore. Interior stated that the construction of 

the north jetty on land of the Cape Hatteras National Seashore would 

block access to a large portion of the spit currently used for 

recreational activities such as fishing, and a large section of the 

spit would be dredged away or used as the site of the proposed sand 

deposition basin.



* The jetty project may not significantly reduce the loss of life at 

Oregon Inlet. Interior points to data which shows that, in some cases, 

the loss of life is not due to conditions at the inlet but rather to 

such factors as alcohol consumption, unfamiliarity with the inlet, 

navigational errors, and the lack of life vests and survival suits. 

According to Interior, these factors would not be corrected by 

construction of the jetties. Interior also raised concerns that the 

construction of hard structures would introduce a new risk to vessels 

traveling through Oregon Inlet, based on accident data from other 

jettied inlets.



For these and other reasons, NPS does not support the construction of 

the proposed jetty project. NPS stated that the jetty project is not 

consistent with its mission of protecting, and it might actually 

impair, the resources and values of the Cape Hatteras National 

Seashore. Further, in May 1982, the Fish and Wildlife Service issued a 

formal determination that the proposed jetty project was not compatible 

with the purposes of the Pea Island National Wildlife Refuge, which was 

established to manage, protect, and restore migratory birds and other 

wildlife.



In addition, in commenting on a draft of the Corps’ August 2001 final 

EIS, the Environmental Protection Agency (EPA) expressed objections to 

the EIS that are similar to the concerns of Commerce and Interior. 

Specifically, in an October 19, 2001, memorandum to the Corps, EPA 

stated that it continues to have objections to the proposed jetty 

project. These include concerns about:



* the potential long-term impacts of the project on a regionally 

important commercial fishery resource, especially disruptions to larval 

fish transport, which EPA believes will be difficult, if not 

impossible, to address;



* the adequacy of the Corps’ proposed mitigation, including whether 

there will be sufficient sand available at critical periods to make the 

proposed sand management plan function as anticipated in preventing 

project-induced erosion of Bodie and Pea Islands;



* the need for the project because of uncertainties associated with 

whether the presumed safety benefits will be fully realized; and:



* the assumed economic benefits due to professional disagreements 

regarding the assumptions used in the project justification.



EPA believes that the project would result in significant environmental 

impacts that should be avoided in order to ensure adequate protection 

of the environment and that these significant issues must be addressed 

more thoroughly in future deliberations on this project and in the 

Corps’ Record of Decision.



The Corps asserts that in its final EIS it adequately addressed the 

concerns raised by Commerce and Interior. Specifically, the Corps said 

that it shortened the length of the jetties and incorporated a weir in 

the north jetty and a sand bypassing system to address the concerns 

raised about fish larvae migration and beach erosion. Furthermore, the 

Corps stated that it plans to monitor whether these actions will work 

and determine whether additional adverse impacts result from 

constructing the jetties. If so, the project will require further 

mitigation. However, neither Commerce nor Interior believes that the 

Corps’ proposed actions would satisfy their concerns.



Because of this impasse, in accordance with regulations under the 

National Environmental Policy Act, on October 16, 2001, Commerce 

formally referred its concerns about the adequacy of the Corps’ EIS to 

the Council on Environmental Quality (CEQ) for its consideration and 

action. The referral process permits federal agencies to bring to CEQ 

interagency disagreements concerning proposed major federal actions 

that might cause unsatisfactory environmental effects. Although 

Interior did not formally refer its concerns to CEQ, it sent a letter 

to CEQ on November 15, 2001, asking the council to consider whether the 

Corps’ final EIS adequately addressed Interior’s environmental 

concerns.



CEQ may take one or more of several actions, including (1) concluding 

that the process of referral and response successfully resolved the 

problem; (2) initiating discussions with the agencies with the 

objective of mediation; (3) holding public meetings or hearings to 

obtain additional views and information; (4) determining that the issue 

is not of national importance and requesting the lead and referring 

agencies to pursue their own decision processes; (5) determining that 

the issue should be further negotiated by the lead and referring 

agencies and that the issue is not appropriate for CEQ’s consideration 

until one or more heads of the agencies report to CEQ that the 

agencies’ disagreements are irreconcilable; (6) publishing its findings 

and recommendations, including, where appropriate, a finding that the 

submitted evidence does not support the position of an agency; and (7) 

submitting, where appropriate, the referral and response, together with 

CEQ’s recommendation, to the President for action. CEQ has initiated 

discussions with Commerce, Interior, and the Corps, and it held a 

public hearing on this issue in December 2001. CEQ is in the process of 

completing its assessment and has not established a date for announcing 

a final decision.



The Corps does not plan to issue its Record of Decision on the project 

until CEQ and GAO issue their final reports. However, the Corps stated 

that until these environmental concerns are resolved and Interior 

indicates it is willing to grant the Corps the permits needed to build 

the project on the federally owned land managed by Interior, the Corps 

does not intend to spend additional public resources to further study 

the economics of the jetty project for improving the safety and 

navigability of Oregon Inlet.



In the meantime, the Corps dredged the Oregon Inlet in 2001 in 

accordance with existing NPS and FWS special use permits. In 

preparation for the Corps’ 2002 dredging effort, according to Interior, 

NPS and FWS assisted the Corps in the preparation of an environmental 

assessment. Based on the cooperatively prepared environmental 

assessment, NPS issued a finding of no significant impact and no 

impairment to park resources and values. NPS then issued a special use 

permit for the 2002 dredging program, which, according to Interior, 

includes a 400-foot wide channel that will require dredging away part 

of the Bodie Island spit. FWS, likewise, issued the Corps a special use 

permit for disposal of dredge material on refuge lands during the 

Corps’ 2002 dredging effort. FWS’s permit allows the Corps to deposit 

about 1 to 2 million cubic yards of dredge spoil on the oceanfront 

beaches of the Pea Island National Wildlife Refuge. According to the 

NPS special use permit, the dredging operation would also eliminate 

approximately 4 acres of wetlands, for which compensatory mitigation 

will be provided by the Corps in the form of enhanced wetlands habitat 

for migratory shorebirds elsewhere on the Bodie Island spit. The Corps’ 

2002 dredging effort is currently underway.



Conclusions:



The Corps states that it has not been able to maintain Oregon Inlet’s 

ocean bar navigation channel at its authorized depth because of the 

inlet’s high-energy conditions, especially during storms, and because 

of funding limitations. While it is difficult, if not impossible, to 

predict the frequency and magnitude of storms that impact on the 

district’s ability to dredge the channel, the district has not 

requested all of the funds it believes are needed to adequately perform 

the dredging. Beginning in fiscal year 2003, the district has decided 

to request the full amount of funds it believes will allow it to 

maintain the channel more reliably.



Although the inlet remains potentially hazardous, we believe that the 

Corps’ economic analysis does not provide a reliable basis for deciding 

whether to proceed with the jetty project. We found significant 

problems with the analysis, including a reliance on outdated and 

incomplete data, the use of unsupported assumptions, and a lack of 

accounting for risk and uncertainty in key variables that could 

significantly affect the project’s benefits and costs. In addition to 

these economic concerns, the Departments of Commerce and the Interior 

do not believe that the Corps has adequately mitigated for 

environmental concerns, including the project’s impact on fish larvae 

migration, beach erosion, and wildlife habitat. Commerce has formally 

referred its concerns to the Council on Environmental Quality for 

resolution. Interior, which also asked the council to consider its 

environmental concerns, has been unwilling to grant the Corps the 

permits needed to construct the project on Interior’s lands. For this 

reason, the Corps does not believe it should spend additional public 

resources reassessing the project’s economic analysis until it has 

assurances that this issue will be favorably resolved. We share the 

Corps’ view that it would not be prudent to spend funds reassessing the 

economics of the project until the council resolves the project’s 

environmental concerns and there is some assurance that the Corps will 

receive the permits needed to build the project.



Recommendations for Executive Action:



Lacking resolution of environmental concerns from the Council on 

Environmental Quality and construction permits from the Department of 

the Interior, we agree with the Corps that it should not pursue further 

development of the Oregon Inlet jetty project. However, if CEQ 

favorably resolves the environmental issues regarding the proposed 

jetty project and the Corps receives assurance that it can obtain the 

permits from Interior that it needs to build the project, in order to 

have a reliable basis for determining whether the project is 

economically justified, we recommend that the Secretary of the Army 

direct the Corps of Engineers to:



* prepare a new and comprehensive economic analysis of the navigation 

project’s costs and benefits that incorporates updated and complete 

data and corrects all errors in calculations and assumptions;



* obtain the information, where possible, that is needed to address the 

uncertainties--such as the extent to which the jetty project could 

affect the activities of all commercial vessels and the extent to which 

areas outside the ocean bar navigation channel could require dredging-

-that could significantly affect project benefits and costs; and:



* submit the revised analysis to the Congress for its use in 

considering future appropriations requests for the project.



Agency Comments and Our Evaluation:



We provided a copy of our draft report to the Secretaries of the Army, 

Commerce, Transportation, and the Interior, for review and comment. 

Overall, the Army, Commerce, and Interior generally agreed with our 

findings and the recommendations of the report. The Department of 

Transportation did not comment on our overall findings and 

recommendations, but offered specific technical comments.



More specifically, the Assistant Secretary of the Army (Civil Works) 

stated that the Department concurs with our finding that the Corps has 

not been able to maintain a safe navigation channel because of the 

inlet’s high-energy environment and the cost of channel dredging. The 

Assistant Secretary also agrees with GAO’s conclusion and 

recommendation that a new economic analysis of the project is needed to 

address project uncertainties and provide a reliable basis for deciding 

whether to proceed with the project. However, the Assistant Secretary 

also agreed that it would not be prudent to expend additional public 

funds to conduct an economic reanalysis until CEQ resolves the 

environmental concerns about the project and Interior provides 

assurances that permits needed to construct the project will be 

granted. In addition, the Assistant Secretary concurred with the 

information GAO provided on the performance of eight similar jetty 

projects, their limitations, and the reasons for those limitations, and 

that the information was useful in designing the jetty project. 

Finally, the Assistant Secretary stated that the Corps continues to 

believe that it has made project design changes and taken adequate 

mitigation measures to accommodate Commerce’s and Interior’s concerns 

and that the jetty project is needed to safely accommodate the large 

trawlers that currently operate through the inlet. The Assistant 

Secretary stated that GAO’s discussion of concerns raised by the other 

agencies repeats concerns raised in earlier comments and in the CEQ 

referral. Accordingly, the Assistant Secretary enclosed a copy of the 

Corps’ response to CEQ. This document is not included with the 

Assistant Secretary’s letter in the report but is available on the Web 

at http://www.whitehouse.gov/ceq/referrals.html.



The Department of the Interior generally agreed with our findings, 

stating that the report is an objective and thorough analysis of a 

complicated project with over three decades of development. It also 

agreed with our recommendations, stating that they are consistent with 

the departmental position and comments over the past 10 years. The 

department also provided clarifications on several technical points, 

which have been included in the report as appropriate.



The Department of Commerce noted that the report was thorough, and it 

concurred with our findings and recommendations, specifically that 

considerable revision of the Corps’ economic and other analyses are 

needed before the feasibility and environmental effects of building 

jetties can be determined. The department also offered several specific 

comments, which we incorporated, as appropriate, in the report.



The Department of Transportation’s U.S. Coast Guard provided oral 

comments on the draft report. Specifically, the Chief, Waterways 

Management Section, District 5, Portsmouth, Virginia, noted that 

neither the GAO report nor the Corps’ economic analysis captured the 

Coast Guard’s costs to maintain the navigation aids at Oregon Inlet 

with or without jetties. The official stated that the service the Coast 

Guard provides is not free, and that costs should be considered in the 

Corps’ economic analysis of the project. The Chief also noted that 

during the past 3 years, the primary buoy-servicing vessel the Coast 

Guard uses at Oregon Inlet has increased in length from 157 feet to 175 

feet, and its draft has increased from 7 to 9 feet. The Chief stated 

that this buoy tender may be the deepest-draft vessel using Oregon 

Inlet, and the Corps should consider the Coast Guard’s operational 

needs in its design of a navigation channel. Otherwise, it will become 

prudent for the Coast Guard to stop servicing aids to navigation in 

Oregon Inlet. We agree that it would be important for the Corps to 

assess the Coast Guard’s costs of maintaining the inlet’s buoys, with 

or without the jetties, when updating its economic analysis. We also 

agree that it is important for the Corps to do sufficient dredging to 

allow Coast Guard vessels access to the buoys for maintenance.



The full text of the comments provided by the Army, Interior, and 

Commerce are included as appendixes VI, VII, and VIII, respectively, in 

this report.



Scope and Methodology:



To assess federal efforts to maintain the authorized depth at Oregon 

Inlet’s ocean bar navigation channel, we reviewed documents provided by 

the Corps’ Wilmington District on the frequency and amount of dredging 

accomplished since 1960. We discussed this dredging history with 

district officials to better understand when and why dredging occurred 

and the types of dredges used to maintain the channel. We also reviewed 

Corps documents that discuss the dredging history of Oregon Inlet and 

show the percentage of time that the district has maintained the 

channel’s authorized depth. We also discussed with district officials 

any circumstances that would affect the district’s ability to dredge 

the channel more frequently and thus maintain the authorized depth more 

consistently. We also reviewed, analyzed, and discussed the district’s 

budget and planning documents for fiscal years 1990 through 2001 to 

ascertain the funding that had been requested, approved, and expended 

for dredging the ocean bar channel at Oregon Inlet. We also discussed 

and obtained information from the Coast Guard regarding its maintenance 

of the navigation buoys at Oregon Inlet to learn of any impediments to 

its efforts.



To assess the extent to which the Corps’ 2001 economic analysis is 

useful for decision making, we compared the Corps’ economic methods and 

assumptions with standard principles of economic analysis, including 

whether the analysis considered reasonable alternatives, quantified and 

monetized all major categories of benefits and costs, measured benefits 

and costs relative to a baseline, used data based on current economic 

conditions, and accounted for risk and uncertainty associated with key 

assumptions and data. In addition, we compared the Corps’ survey 

methods with standard principles for sampling populations and 

developing and conducting surveys. We focused our review on the Corps’ 

estimates of dredging and jetty costs and on the estimated benefits 

that had the greatest impact on the Corps’ benefit-cost ratio 

(commercial fishing, recreational boating, vessel losses and damages, 

accidental deaths averted, and land preservation). We discussed the 

benefit-cost analysis with Corps officials and, where possible, we 

collected supporting documentation from which to verify the Corps’ 

analysis. In addition, we reviewed agency and public comments about the 

Corps’ economic analysis. Moreover, we collected updated information 

pertaining to the various categories of benefits and costs to ascertain 

if conditions had changed that would alter the results of the Corps’ 

analysis. For example, to verify Corps and consultant data on lives 

lost, vessels lost, and damage at Oregon Inlet and to develop new data, 

we obtained information from Coast Guard records to determine which 

cases were likely attributable to Oregon Inlet conditions. More details 

of our work on the components of the economic analysis are contained in 

appendix IV.



To obtain information on the performance of similar jetty projects, we 

obtained data from Corps researchers and Corps district offices on 

jetty projects at coastal inlets with design features similar to those 

planned for Oregon Inlet, mainly dual jetties and incorporated weirs. 

We identified eight similar jetty projects--seven built by the Corps 

and one built by the City of Virginia Beach, Virginia, for which the 

Corps maintains the navigation channel. The eight projects are under 

the jurisdiction of six Corps districts: Jacksonville, Florida; Mobile, 

Alabama; Wilmington, North Carolina; Galveston, Texas; Charleston, 

South Carolina; and Norfolk, Virginia. To collect information on how 

these similar jetty projects have performed, we developed a structured 

interview document that included a standard list of questions about 

each jetty’s physical features, purpose, and performance 

characteristics, such as the operation of the weir and its impacts on 

dredging and beach erosion. We then interviewed staff responsible for 

the projects to obtain answers to the questions. We did not verify the 

answers that district officials provided.



To determine whether the Corps’ Wilmington District applied lessons 

learned from similar jetty projects in its design of the Oregon Inlet 

jetty project, we interviewed its engineering staff about the 

information they used in developing designs for the proposed Oregon 

Inlet jetties. Wilmington staff said they relied in part on lessons 

learned from the operations of the jetty project at Masonboro Inlet, 

North Carolina, in designing the project for Oregon Inlet. The staff 

also identified the Corps’ internal guidance as helping with the 

design. We discussed the lessons learned with the staff and reviewed 

Corps planning and engineering documents to verify that the lessons had 

been applied. We also discussed with Wilmington District staff, other 

federal agency officials, and academic experts (1) the accuracy of 

estimates of sand transport used in designing the jetty project and (2) 

the potential for applying lessons learned from one jetty project to 

another.



To identify concerns raised by the Departments of Commerce and the 

Interior about the development of the jetty project, we reviewed 

comments on the Corps’ EIS and design documents and documents developed 

by Commerce and Interior that discussed their concerns. We discussed 

the concerns with officials in these departments to better understand 

the issues. We also met with Wilmington District staff and other 

project proponents, such as North Carolina state government officials 

and fishing industry representatives, and discussed the departments’ 

concerns with them in order to determine the proponents’ views of these 

concerns and to learn of any planned or completed mitigating actions. 

We also reviewed the Department of Commerce’s referral and Department 

of the Interior’s letter and supporting materials sent to the Council 

on Environmental Quality citing their objections to the Corps’ EIS. We 

also discussed many of the environmental issues with various opponents 

of the project, such as environmental groups and some academic experts, 

in order to better understand the issues and their views.



We conducted our work between March 2001 and September 2002 in 

accordance with generally accepted government auditing standards.



As arranged with your offices, unless you publicly announce the 

contents of this report earlier, we plan no further distribution until 

30 days from the report date. At that time, we will send copies of this 

report to the Secretaries of Defense, Commerce, and the Interior; the 

Director, Office of Management and Budget; and other interested 

parties. We also will make copies available to others upon request. In 

addition, the report will be available at no charge on the GAO 

Web site at http://www.gao.gov. If you or your staffs have any 
questions, 

please call me at (202) 512-3841. Key contributors to this report are 

listed in appendix IX.



(Ms.) Gary L. Jones

Director, Natural Resources and Environment:

Signed By Gary L. Jones:





Appendixes :



Appendix I: The Corps’ Process for Developing Water Resource Projects:



Generally, the Corps becomes involved in a water resource project when 

the local community perceives a need and contacts the Corps for 

technical assistance. If the Corps does not have the statutory 

authority required to study the project, the Congress must provide 

authorization. Generally, this begins with local officials contacting 

their congressional delegation. After receiving authorization, 

generally through a committee resolution or legislation, and an 

appropriation, a Corps district office conducts a preliminary 

(reconnaissance) study on how the problem could be addressed and 

whether further study is warranted.



If further study is warranted, the Corps typically seeks agreement from 

the local sponsor to share costs for a feasibility study. The Congress 

may appropriate funds for the feasibility study, including an economic 

analysis, which is conducted by the Corps district office. The 

feasibility report makes recommendations on whether the project is 

worth pursuing and how the water resource problem should be addressed. 

In conjunction with the feasibility study, the Corps must also perform 

the appropriate environmental study under the requirements of the 

National Environmental Policy Act. After public comments on the 

environmental study are considered, the Chief of Engineers transmits 

the final versions of the environmental and feasibility reports to the 

Congress through the Assistant Secretary of the Army for Civil Works 

and the Office of Management and Budget. As long as appropriations are 

available, the Corps will also prepare a preconstruction engineering 

and design report, which is provided to the authorizing committees. The 

Congress may authorize the construction of the project in a Water 

Resources Development Act or other legislation.



Project construction will occur once the authorized project is included 

in the President’s budget and the Congress appropriates the federal 

share of funds to start the project. Upon appropriation of needed 

funds, and before construction can begin, the Secretary of the Army and 

nonfederal sponsors generally sign a formal project cooperation 

agreement. The Corps district office completes the necessary 

engineering and design work to develop plans and specifications for 

construction. Private contractors managed by the Corps do the 

construction work.



[End of section]



Appendix II: Chronology of Significant Events for the Oregon Inlet 
Jetty 

Project, 1950 through 2002:



Date:



Event:



05/17/50:



P.L. 81-516, The River and Harbor Act of 1950 authorized the Corps to 

dredge the ocean bar navigation channel to a depth of 14 feet.



04/17/63:



Committee on Public Works of the U.S. Senate adopts a resolution to 

initiate a study of the Oregon Inlet Jetty Project.



09/26/63:



Committee on Public Works of the U.S. House of Representatives adopts a 

resolution to initiate a study of the Oregon Inlet Jetty Project.



04/30/69:



Corps submits a favorable report to the Secretary of the Army.



03/18/70:



Secretary of the Army submits the Corps’ report to the Congress 

recommending that the ocean bar navigation channel be deepened from 14 

feet to 20 feet, stabilizing Oregon Inlet with jetties, providing a 

means for bypassing sand across the inlet, and creating a 15-acre 

harbor at Wanchese. The benefit-cost ratio is estimated to be 1.4.



12/31/70:



The River and Harbor Act of 1970, Public Law 91-611, Section 101, 

authorizes the Oregon Inlet Jetty Project.



04/15/77:



Corps releases drafts of the Phase I General Design Memorandum (GDM)-

Plan Formulation and Environmental Impact Statement (EIS) for the 

project, supporting the basic plan authorized by the Congress.



06/17/77:



Department of the Interior comments on the Phase I GDM and Draft EIS 

state that the principal issues involve jetty construction and impacts 

on fish larvae migration. The comments state that the proposed project 

would result in significant impacts on parklands and that documents do 

not adequately address sand bypassing.



07/29/77:



Corps publishes Phase I of the GDM-Plan Formulation.



12/78:



Contract is awarded by North Carolina to enlarge the harbor at 

Wanchese.



05/02/79:



Interior meets with the Corps to inform it of the need for special use 

permits for construction on Interior lands. The Corps agrees to prepare 

a supplement to the Final Environment Impact Statement.



07/12/79:



The Corps sends a letter to the Fish and Wildlife Service (FWS) 

Regional Director outlining right-of-way needs for construction, 

operation, and maintenance of the jetty project and requesting a 

Cooperative Use Agreement for placement of jetties on Pea Island 

National Wildlife Refuge.



08/03/79:



The NPS initiates formation of a Coastal Advisory Committee, which 

would be known as the Inman Panel.[Footnote 22] Later that month the 

panel issues a report outlining the deficiencies in the Corps’ proposal 

and concluding that the project would adversely affect the shoreline 

environment.



09/21/79:



The Corps distributes a draft of a Supplement to the Final EIS to 

federal agencies, which is later designated as Supplement I. The 

purpose of the supplement is to discuss refinement of project features, 

correct errors in the earlier EIS, and address environmental concerns.



12/03/79:



Interior provides comments to the Corps on the draft Supplement to the 

Final EIS, stating that Interior is not “in accord with the current 

project design.” The primary concerns of Interior are that (1) the 

jetties would accelerate already high rates of erosion near the inlet 

and (2) the jetties would alter normal longshore sand transport and 

likely cause “serious erosion problems well beyond the project area.”:



08/07/80:



The Inman Panel releases a second report entitled Potential Effects of 

the Proposed Oregon Inlet Jetties on Shore Processes Along the Outer 

Banks of North Carolina.



09/80:



The Corps publishes the Phase II GDM-Project Design.



09/09/80:



Interior informs the Corps that neither the National Park Service nor 

the FWS finds the jetties consistent with the purpose for which land 

under its jurisdiction was established. DOI declines to issue permits 

for the jetties and remains opposed to the project.



12/03/80:



The Corps provides Interior with the Phase II GDM. The document 

provides revised details on the design and construction of the dual 

jetty project and a sand bypassing plan.



12/28/80:



An Interior memo outlines serious environmental concerns regarding the 

construction of the jetties, for example, accelerated beach erosion and 

blockage of larval fish passage, and expresses doubts about the success 

of a Corps sand bypassing program. Interior supports a dredging-only 

alternative.



03/81:



North Carolina completes construction of the harbor at Wanchese and a 

seafood industrial park.



07/06/81:



Interior Secretary denies permits for the jetty project and states that 

this decision is based on the project’s incompatibility with use of NPS 

and FWS lands. The Secretary directs the FWS and NPS to work with the 

Corps to develop an alternative to the jetties.



11/24/81:



The Assistant Secretary of the Army (Civil Works) asks Interior for a 

decision on the Corps’ request for permits to use FWS land and the 

transfer of jurisdiction of land from the NPS.



12/17/81:



Interior requests that the Corps examine the feasibility of the 

dredging-only alternative and that the analysis of a dredging-only 

alternative be completed before the Corps pursues the option of jetty 

construction.



12/22/81:



The Assistant Secretary of the Army (Civil Works) authorizes the Corps 

to undertake a comprehensive evaluation of a dredging-only alternative 

recommended by Interior.



05/11/82:



The Corps holds a scoping meeting and announces its intention to 

prepare a second supplement to the Final EIS in order to evaluate the 

dredging-only alternative recommended by Interior and to design changes 

for the jetties.



04/01/83:



The Corps releases its report on the DOI dredging-only plan. The 

report, entitled Feasibility Study, Dredging/Near-Shore Disposal Plan, 

Oregon Inlet, North Carolina, concludes that Interior’s dredging-only 

alternative is “functionally infeasible” because it would produce 

“catastrophic and unacceptable” beach erosion.



04/21/83:



Interior Secretary meets with the Assistant Secretary of the Army 

(Civil Works), the North Carolina governor, and the state’s 

congressional delegation. Interior Secretary reiterates that the agency 

is unable to issue special use permits for jetty construction on its 

land.



06/14/83:



Bills are introduced in the Congress (H.R. 3288 and S. 1471) to 

authorize the transfer of land from Interior to the Corps for 

construction of the jetty project. Neither bill passes.



09/83:



The Corps publishes Supplement I to the Phase II General Design 

Memorandum addressing jetty spacing, structural design, hydraulic 

stability, subsurface analysis, sand bypassing, and a reanalysis of 

navigation channel dimensions.



02/84:



The Corps publishes an economic analysis of the project as directed by 

the Assistant Secretary of the Army (Civil Works) to update an earlier 

analysis.



08/13/84:



The Corps issues a draft of Supplement II to the Final EIS. The 

document states that the dredging-only alternative with near-shore 

disposal has been evaluated and found unacceptable. The preferred 

alternative is the dual jetty project with design modifications.



11/14/84:



Interior’s comments on the draft Supplement II to the Final EIS note 

that (1) the dredging-only alternative is not adequately addressed, (2) 

the project would accelerate erosion on Pea Island, and (3) the project 

may be referred to the Council on Environmental Quality.



12/05/84:



An Office of Management and Budget (OMB) letter to the Corps states 

concern that project costs will substantially exceed benefits and that 

significant adverse environmental impacts could add to total project 

costs. OMB requests an independent analysis.



05/85:



The Corps issues final Supplement II to the Final EIS finding the 

dredging-only alternative unacceptable and making the jetties the 

preferred alternative of the Corps.



08/14/85:



Interior comments on the Final Supplement II to the Final EIS stating 

that, overall, Interior is still opposed to the jetties and supports a 

dredging-only alternative.



07/87:



The Kearney/Centaur Company releases A Reassessment of the Economic 

Feasibility of the Oregon Inlet Project. This detailed evaluation of 

project economics by a consultant hired by the Corps at OMB’s request 

concludes that project costs would exceed benefits.



04/88:



The state of North Carolina submits a report responding to the economic 

analysis by Kearney/Centaur.



06/20/89:



FWS issues a right-of-way permit to the North Carolina Department of 

Transportation for constructing a terminal groin[Footnote 23] on the 

north end of Pea Island National Wildlife Refuge to protect the bridge 

over Oregon Inlet. Two days later, the Corps issues permits for 

construction.



11/89:



North Carolina awards a contract for construction of the terminal groin 

to reduce erosion at north end of Pea Island and protect Bonner Bridge 

using the Corps’ design for a 3,125-foot structure with the same 

dimensions and same location as the landward section of the proposed 

south jetty.



07/90:



The Corps releases its third economic analysis of project, entitled 

1990 Update of 1984 Economic Analysis. This report shows lower initial 

construction costs due to the separate construction of the terminal 

groin.



12/90:



The Secretary of the Interior sends a letter to the Secretary of the 

Army providing criteria the Corps needs to meet to obtain Interior’s 

approval of the project. The criteria include (1) approval of the 

project by the Office of Management and Budget; (2) assurance that the 

project is legal and compatible with the park and refuge; and (3) 

assurance that the project’s environmental impacts are assessed and 

found acceptable.



01/91:



A joint Interior and Corps committee is formed to develop an acceptable 

sand management plan.



03/91:



Construction of the terminal groin on Pea Island is completed.



12/31/91:



The joint Interior-Corps committee releases a report evaluating their 

differences over the scientific and engineering aspects of the jetty 

project. A report by Interior consultants, issued on the same date to 

the Secretary of the Interior, concludes that the jetties would have 

significant unavoidable large-scale impacts on the inlet and the 

adjacent barrier islands and discusses the ecological implications of 

project, including the impact on fish larvae migration.



10/28/92:



The Interior Secretary issues two conditional permits to the Corps for 

use of Interior lands for jetty construction, contingent on completion 

of project plans and environmental studies.



01/28/93:



U.S. Senator Jesse Helms introduces S. 192, a bill that would require 

the Corps to carry out the construction and operation of the jetty and 

sand transfer system regardless of the final Interior position. The 

bill also would exempt the project from any permit requirements, 

including those issued by Interior.



06/15/93:



A new Interior Secretary rescinds the conditional permits that would 

have allowed the Corps to use Interior lands for the construction of 

the Oregon Inlet jetties. The Secretary states that Interior would 

revisit this decision when environmental studies on the project have 

been completed.



10/94:



The Corps initiates coordination with Interior on the design of a sand 

management plan for the Oregon Inlet Project.



01/31/95:



U.S. Representative Walter Jones introduces H.R. 758 entitled the 

“Oregon Inlet Protection Act of 1995.” The bill would require the Corps 

to carry out construction and operation of the jetties project. The 

bill would allow the Corps to designate the land required for the 

project and notify the Interior Secretary of the designation.



07/95:



The Corps releases a Feature Design Memorandum on the sand management 

plan that recommends a sand bypassing system that will emulate natural 

shoreline processes when the jetties are in place.



07/18/96:



The Senate Subcommittee on Parks, Preservation, and Recreation holds a 

hearing on S. 988, a bill directing Interior to transfer administrative 

jurisdiction over certain land to the Secretary of the Army to 

facilitate construction of the jetties and the sand transfer system. 

Interior opposes the bill because of its impact on park and refuge 

land. The Assistant Secretary of the Army (Civil Works) testifies that 

studies must be completed before construction of the project can begin, 

and that it would be premature for the Corps to accept jurisdiction of 

the land required for construction. The bill is not passed.



01/04/99:



The Corps releases drafts of Supplement No. 2 to the GDM and Supplement 

III to the project EIS. In the EIS, the Corps’ preferred alternative is 

construction of the dual jetty project and implementation of a sand 

management plan. In the GDM, the Corps proposes a new jetty design that 

shortens each jetty by approximately 1,000 feet, eliminates the sand-

blocking central barrier within each jetty, and adds a 1,000-foot weir 

section in the north jetty over which sand is expected to move into a 

60-acre deposition basin.



03/04/99:



The National Marine Fisheries Service’s (NMFS) comments on the January 

1999 EIS state that “the potential for significant and adverse long-

term impacts to nationally important living marine resources is such 

that the NMFS has no recourse but to recommend that the jetties not be 

built.”:



03/22/99:



Interior’s comments note deficiencies in Supplement III to the EIS and 

reiterate that project goals could and should be met with a dredging-

only program rather than the dual jetty. The comments state that 

Interior will consider referring the jetty project to the Council on 

Environmental Quality.



05/09/00:



U.S. Senator Jesse Helms attaches a rider (the Oregon Inlet, North 

Carolina, Flood Control Improvements) to the fiscal year 2001 

Agriculture Appropriations Bill that would have transferred the land to 

build the jetties from the jurisdiction of Interior to the Corps.



07/12/01:



FWS provides the Corps with a Final Fish and Wildlife Coordination Act 

report for the project. The report recommends that (1) the Corps 

abandon plans for a dual jetty project due to the magnitude of 

environmental consequences and (2) the Corps develop a dredging-only 

program to achieve project goals.



09/01:



The Corps releases final versions of Supplement No. 2 to the GDM and 

Supplement III to the project EIS. The Corps’ preferred alternative 

remains construction of the dual jetty project and implementation of a 

sand management plan.



10/16/01:



Commerce refers the project to the Council on Environmental Quality 

(CEQ), stating that the project’s construction would cause unacceptable 

environmental harm to commercial and recreational fishery resources.



12/12/01:



CEQ holds a public meeting in Manteo, North Carolina, on the dual jetty 

and weir system project, receives briefings from involved agencies, and 

visits the site of the proposed project.



04/8/02:



The Corps issues an Environmental Assessment for maintenance of the 

channel that includes dredging a 600-foot wider channel on the north 

side of the inlet, removing 26 acres of Bodie Island, and placing the 

dredged material on Pea Island. The assessment and draft Finding of No 

Significant Impact are released for a 30-day public comment period.



05/02:



Interior submits comments on the Environmental Assessment for the 

channel maintenance, recommending that a 400-foot wider channel be 

selected as the preferred alternative in order to minimize ecological 

impacts.



07/02:



Interior issues two Special Use Permits--one by NPS and one by FWS--to 

the Corps to construct a wider channel on the north side of the inlet, 

which would remove over 400 feet of the Bodie Island barrier spit 

within the Cape Hatteras National Seashore and deposit the 1 to 2 

million cubic yards of dredge spoil on the oceanfront beaches of Pea 

Island. The construction would eliminate approximately 4 acres of 

wetlands, for which compensatory mitigation will be provided in the 

form of enhanced wetland habitat for migratory shorebirds elsewhere on 

the Bodie Island spit.



[End of section]



Appendix III: Approved Oregon Inlet Dredging Operations That Were Not 

Performed:



As shown in table 3, for some of the fiscal years from 1990 through 

2001, the Wilmington District Office did not perform numerous approved 

dredging operations in the Oregon Inlet ocean bar navigation channel 

and, as a result, did not remove thousands of cubic yards of sand from 

the channel. The District Office did not perform these operations 

because the funds were used on other, higher priorities within the 

district.



Table 3: Approved Oregon Inlet Dredging Operations That Were Not 

Performed for Some of the Fiscal Years from 1990 through 2001:



Fiscal year: 1990; Operations not performed: Dredge channel with two 

Corps side-cast dredges; Approved funding: $860,000; Cubic yards of 

sand planned for removal: Not available.



Operations not performed: Fiscal year : Dredge channel with a hopper 

dredge; Approved funding: Fiscal year : $845,000; Cubic yards of sand 

planned for removal: Fiscal year : Not available.



Fiscal year: 1994; Operations not performed: Dredge channel with two 

Corps side-cast dredges; Approved funding: $1,239,000; Cubic yards of 

sand planned for removal: Not available.



Operations not performed: Fiscal year : Dredge channel with a hopper 

dredge; Approved funding: Fiscal year : $2,809,000; Cubic yards of sand 

planned for removal: Fiscal year : Not available.



Fiscal year: 1996; Operations not performed: Dredge channel with two 

hopper dredges; Approved funding: $1,848,000; Cubic yards of sand 

planned for removal: 622,216.



Fiscal year: 1998; Operations not performed: Dredge channel with a 

Corps side-cast dredge; Approved funding: $664,000; Cubic yards of sand 

planned for removal: 601,067.



Operations not performed: Fiscal year : Dredge channel with a hopper 

dredge; Approved funding: Fiscal year : $929,000; Cubic yards of sand 

planned for removal: Fiscal year : 362,279.



Fiscal year: 1999; Operations not performed: Dredge channel with a 

Corps side-cast dredge; Approved funding: $506,000; Cubic yards of sand 

planned for removal: 418,958.



Operations not performed: Fiscal year : Dredge channel with a hopper 

dredge; Approved funding: Fiscal year : $949,000; Cubic yards of sand 

planned for removal: Fiscal year : 164,629.



Fiscal year: 2000; Operations not performed: Dredge channel with three 

Corps side-cast dredges; Approved funding: $813,000; Cubic yards of 

sand planned for removal: 663,215.



Operations not performed: Fiscal year : Dredge channel with a hopper 

dredge; Approved funding: Fiscal year : $201,000; Cubic yards of sand 

planned for removal: Fiscal year : 187,984.



Note: Costs are expressed in constant 1997 dollars and reflect unspent 

amounts for dredging the ocean bar channel. In addition, there were 

some years when the Corps spent more funds than were made available for 

dredging but the quantity dredged was 1,889,504 cubic yards less than 

was planned. Totals may not add due to rounding.



[A] Actual total exceeds the amount shown because data from some years 

were not available.



Source: GAO analysis of data provided by the Corps’ Wilmington District 

Office.



[End of section]



Appendix IV: Review of Corps’ Economic Analysis of the Proposed Oregon 

Inlet Jetty Project:



This appendix reviews the Corps’ analysis of the benefits and costs of 

the recommended jetty project for Oregon Inlet. In general, the Corps’ 

analysis has limitations that undermine its usefulness for assessing 

the economic tradeoffs between the current 14-foot dredging program and 

the Corps’ preferred alternative of a jetty system with a 20-foot 

navigation channel. Specifically, the Corps’ analysis (1) failed to 

consider intermediate channel depths between 14 feet and 20 feet, (2) 

used outdated data to estimate the benefits to trawlers and did not 

account for the effects of the proposed jetty project on smaller 

commercial fishing vessels, (3) used some incorrect and outdated data 

to estimate vessel losses and damages, (4) used questionable survey and 

sampling techniques to estimate recreational benefits, (5) did not 

value land protected from erosion according to federal guidelines, and 

(6) did not fully account for risk and uncertainty in key variables 

used in the analysis. In addition, we also identified other 

limitations, including the fact that the Corps did not account for the 

economic value of the lives that might be saved by the jetty project; 

in addition, its estimate of project cost does not include more recent 

expenditures and is based on an overly optimistic assumption. These 

latter limitations are discussed in the report.



The Corps Did Not Consider Alternative Channel Depths between 14 Feet 

and 20 Feet:



In conducting its economic analysis, the Corps considered three 

alternatives: (1) dredging a 20-foot channel in the spring, (2) 

dredging a 20-foot channel in the fall, and (3) constructing dual rock 

jetties with a sand bypassing system, along with a 20-foot channel. The 

Corps did not analyze intermediate channel depths between the current 

14 feet and the authorized 20 feet. As shown in table 4, the Corps 

estimated the benefits and costs associated with three 20-foot channel 

alternatives--including the proposed jetty project--relative to the 

current 14-foot dredging program. Based on this analysis, the Corps 

determined that the proposed jetty project would provide greater net 

benefits and a higher benefit-cost ratio than either the current 

program or the other two 20-foot alternatives. Corps officials said 

they considered only alternatives that would achieve the 20-foot 

channel depth because analyses the Corps conducted in 1970 and again in 

1984 demonstrated that the 20-foot channel was needed to reliably 

enable the existing fleet, including 75-foot commercial fishing 

vessels, to pass safely through the ocean bar navigation channel. The 

Corps’ 1970 analysis, which served as the basis for the congressional 

authorization in 1970, found that that a 20-foot channel would be 

economically superior to other channel depths (including 14 feet) 

because it would accommodate existing trawlers and attract some 

additional trawlers and, therefore, result in the plan that has the 

greatest net benefits.



However, federal guidance for evaluating water resource plans such as 

the proposed Oregon Inlet jetty project states that alternative plans 

should not be limited to those that the Corps could implement under 

existing authorities. Alternative plans should be formulated in a 

systematic matter to ensure that all reasonable alternatives are 

evaluated.[Footnote 24] In addition, according to the state of North 

Carolina, trawlers used the inlet far less frequently than smaller, 

shallower-draft vessels from 1999 through 2001. For example, of the 

approximately 3,900 average annual commercial fishing trips through the 

inlet from 1999 through 2001, 83 percent were by smaller commercial 

fishing vessels.[Footnote 25] Because these vessels have a shallower 

draft, they may not be as dependent as trawlers upon the deeper channel 

depths.[Footnote 26] Moreover, although the smaller vessels might 

benefit from an increase in the current 14-foot channel depth, the 

economically optimal depth, taking into account all vessels (commercial 

and recreational) currently using Oregon Inlet, may be less than 20 

feet. Consequently, by not including an analysis of the benefits and 

costs of intermediate channel depths, the Corps’ analysis is less 

useful for decision making because it does not clearly demonstrate that 

the 20-foot channel depth is economically superior to other depths.



Table 4: Comparison of Estimated Annual Benefits and Costs of 

Alternatives for Achieving a 20-Foot-Deep Navigation Channel for Oregon 

Inlet:



Categories of impacts: Increased benefits; Reduced operating costs of 

commercial fishing vessels; Alternatives for achieving 20-foot-deep 

channel: Dredging: $2,011,000; Alternatives for achieving 20-foot-deep 

channel: Dredging: $2,011,000; Alternatives for achieving 20-foot-deep 

channel: Jetty project: $2,011,000.



: Value of increased recreational boating trips; Alternatives for 

achieving 20-foot-deep channel: Dredging: : $3,367,000; Alternatives 

for achieving 20-foot-deep channel: Dredging: : $3,367,000; 

Alternatives for achieving 20-foot-deep channel: Jetty project: : 

$3,367,000.



: Reduced costs associated with reduced vessel losses and damages; 

Alternatives for achieving 20-foot-deep channel: Dredging: : $552,000; 

Alternatives for achieving 20-foot-deep channel: Dredging: : $552,000; 

Alternatives for achieving 20-foot-deep channel: Jetty project: : 

$552,000.



: Erosion protection; Alternatives for achieving 20-foot-deep channel: 

Dredging: : $0; Alternatives for achieving 20-foot-deep channel: 

Dredging: : $0; Alternatives for achieving 20-foot-deep channel: Jetty 

project: : $1,000,000.



: Value of other categories [A]; Alternatives for achieving 20-foot-

deep channel: Dredging: : $307,000; Alternatives for achieving 20-foot-

deep channel: Dredging: : $307,000; Alternatives for achieving 20-foot-

deep channel: Jetty project: : $307,000.



: Accidental deaths prevented (over 50 years); Alternatives for 

achieving 20-foot-deep channel: Dredging: : 14; Alternatives for 

achieving 20-foot-deep channel: Dredging: : 14; Alternatives for 

achieving 20-foot-deep channel: Jetty project: : 14.



: Total increased benefits; Alternatives for achieving 20-foot-deep 

channel: Dredging: : $6,237,000; Alternatives for achieving 20-foot-

deep channel: Dredging: : $6,237,000; Alternatives for achieving 20-

foot-deep channel: Jetty project: : $7,237,000.



Categories of impacts: Increased costs; Construction and maintenance; 

Alternatives for achieving 20-foot-deep channel: Dredging: 

$10,601,400; Alternatives for achieving 20-foot-deep channel: 

Dredging: $8,148,400; Alternatives for achieving 20-foot-deep channel: 

Jetty project: $4,520,000.



Categories of impacts: Net benefits (increased benefits minus increased 

costs); [Empty]; Alternatives for achieving 20-foot-deep channel: 

Dredging: -$4,364,400; Alternatives for achieving 20-foot-deep 

channel: Dredging: -$1,911,400; Alternatives for achieving 20-foot-

deep channel: Jetty project: $2,717,000.



Categories of impacts: Benefit-cost ratio (increased benefits divided 

by increased costs); [Empty]; Alternatives for achieving 20-foot-deep 

channel: Dredging: 0.59; Alternatives for achieving 20-foot-deep 

channel: Dredging: 0.77; Alternatives for achieving 20-foot-deep 

channel: Jetty project: 1.6.



[A] Includes categories such as charter boat income and reduced 

maintenance of navigation aids.



Source: U.S. Army Corps of Engineers 2001 General Design Memorandum.



[End of table]



Corps’ Analysis of Benefits to Commercial Fishing Vessels Relied on 

Outdated Trip Data and Excluded Certain Vessels:



In its 2001 General Design Memorandum, the Corps determined that the 

proposed jetty project would generate about $2 million in annualized 

commercial fishing benefits. To derive this estimate, the Corps relied 

primarily on a 1987 consultant’s study of trawler trips taken in the 

mid-1980s. That study determined that 234 trawlers were forced to 

detour to alternative inlets or ports on average about 42 percent of 

the time, adding about 14 hours to the length of their fishing trips. 

Thus, the study estimated that trawlers lost about 27,163 hours 

detouring to alternative inlets. Assuming that the proposed jetty 

project would save commercial fishing vessels these hours, the Corps 

multiplied the hours by an estimate of the hourly cost to operate a 

commercial fishing vessel ($80.21, including fixed and variable 

operating costs) to estimate the value of the time savings as 

$2,179,000. The Corps divided $2,179,000 by the 17.9 million pounds of 

fish estimated to have been landed through Oregon Inlet by all 

commercial vessels in the mid-1980s to obtain the per-pound savings of 

12.2 cents. The Corps then applied the per-pound savings to two 

different estimates of long-term fish harvests: one based on 

projections developed by the National Marine Fisheries Service and one 

based on projections developed by the state of North Carolina. In 

addition, the Corps conducted an uncertainty analysis on each 

projection to incorporate variability in natural fish populations and 

the effectiveness of management plans. Based on the two projections and 

the uncertainty analysis, the Corps estimated that from 16,758,000 to 

23,313,000 pounds of fish could be available for harvest annually over 

the 50-year life of the jetty project. Multiplying these projections by 

the per-pound savings of about 12.2 cents, the Corps estimated that 

annualized benefits of the proposed jetty project would range from 

$2,011,000 to $2,798,000.



However, recent data from the state of North Carolina Division of 

Marine Fisheries commercial fishing trip ticket program suggest that 

trawlers are taking fewer trips than they did in the mid-1980s. 

Moreover, trawlers would not likely save the fixed-costs portion of 

their hourly operating costs even if the proposed jetty project were 

built.[Footnote 27] To illustrate how the Corps’ benefit estimate would 

change using the more recent trawler trip data, we adjusted the Corps’ 

commercial fishing vessel benefits analysis to account for trawler 

trips taken from 1999 through 2001. In addition, we adjusted the Corps’ 

analysis to exclude the fixed costs that would not likely be affected 

by the proposed jetty project. After making these adjustments, we found 

that the Corps estimate of commercial benefits would be reduced by 

about 90 percent. Nonetheless, the Corps’ analysis excludes smaller 

commercial fishing vessels; including these vessels could increase this 

adjusted estimate of benefits.



For example, according to data obtained from the state of North 

Carolina, vessels 55 feet or longer (defined by the Corps as trawlers) 

averaged 679 trips through the inlet from 1999 through 2001.[Footnote 

28] Based on these trips and the 1987 consultant’s estimate of the 

fraction (0.42) of trips delayed and the average length of the delay 

(14 hours), trawlers might have been delayed by about 4,000 hours 

annually over this period. Multiplying the hours delayed (4,000) by the 

Corps’ hourly operating cost for a trawler (about $68.00 per hour, 

exclusive of fixed costs) gives an estimated potential annual savings 

of about $272,000. Dividing the annual savings ($272,000) by the 

average number of pounds landed by trawlers through Oregon Inlet from 

1999 through 2001 (8.6 million pounds or 39 percent of the total 

commercial landings) provides potential savings of about 3 cents per 

pound. We applied the fraction (0.39) of trawler catch to the Corps’ 

two projections of future fish harvests to obtain an estimate of the 

pounds of fish that trawlers would be expected to harvest based on 

current data. For example, based on the current harvest data and the 

long-term projections developed by the Corps, trawlers might harvest 

from about 6,500,000 pounds to 9,100,000 pounds of fish annually. We 

multiplied the two estimates of the trawler harvest by 3 cents to 

obtain the estimate of annual operating cost savings. We then estimated 

the present value and annualized over the 50-year period using the 

Corps’ discount rate of 7.125 percent. Thus, adjusting the Corps’ 

analysis in this way generates annualized benefits ranging from about 

$194,000 to $270,000, or about 90 percent less than the Corps 

estimated.[Footnote 29]



The Corps used two other methods to verify the analysis conducted using 

the consultant’s 1987 study. First, the 2001 GDM refers to a 1990 Corps 

economic analysis that found commercial fishing vessels were delayed by 

17,666 hours because of Oregon Inlet conditions, incurring additional 

costs of 11.4 cents per pound to land fish. However, the Corps estimate 

is not based on the number of trips or landings made by trawlers in 

recent years. Second, based on a 1995 study by a consultant, the Corps 

assumed that 56 full-time vessels were forced to detour eight trips per 

year. In addition, the Corps assumed that other vessels would use 

Oregon Inlet if the jetty project were built. For example, the Corps 

assumed that 100 additional part-time and/or transient vessels would 

use Oregon Inlet to land fish and another 100 vessels would use Oregon 

Inlet seeking a harbor of refuge during storms. However, the Corps 

could not provide us with the documentation to verify the number of 

full-time vessels, total trips taken, trips detoured, number of 

transient vessels using the inlet, or the number of vessels that might 

seek refuge during storms.



Accounting for the effect of the proposed jetty project on smaller 

fishing vessels could increase this adjusted estimate of the benefits 

to commercial fishing vessels. Nonetheless, because these smaller 

vessels have a shallower draft than trawlers, they may not be as 

affected by the sand accumulations in the ocean bar navigation channel 

that can be hazardous to trawlers. For this reason, the extent to which 

smaller vessels might benefit from the jetty project is uncertain. In 

addition, to the extent that trawlers relocate from other fishing ports 

(for example, Norfolk) to Wanchese, North Carolina, as a result of the 

jetty project, estimated benefits to trawlers could be higher (after 

netting out transfers between the two regions). Moreover, to the extent 

that trawler captains are detoured or delayed more or less often than 

we assumed, the estimated benefits could be higher or lower. Several 

trawler captains told us that there are fewer detours available to them 

than in the past. According to these captains, the Ocracoke Inlet and 

the Atlantic Intracoastal Waterway from Norfolk, Virginia, to Wanchese, 

North Carolina, are too shallow for trawlers to use as a way to avoid 

passing through Oregon Inlet. These captains said that instead of 

traveling to alternative inlets or ports, they often wait for high tide 

at Oregon Inlet in order to increase the distance between the keel of 

their vessel and the channel bottom. By waiting for high tide, vessels 

might be delayed less time per trip than is assumed in either the 

Corps’ analysis or this adjusted analysis. However, no comprehensive 

data are available with which to verify the average length of time 

vessels are currently delayed or to evaluate the effects of conditions 

in Oregon Inlet on the operating efficiency of the current trawler 

fleet or smaller commercial fishing vessels.



Corps’ Estimate of Vessel Losses and Damages Is Based on Unsupported 

Assumptions and Outdated Data:



The Corps estimated that the recommended jetty project would generate 

annualized benefits of $552,000--$160,000 in reduced vessel losses and 

$392,000 in reduced damages to commercial fishing vessels. The Corps 

anticipates that the jetty project would generate these benefits by 

reducing the high waves and sand accumulations in the inlet that 

contribute to vessel losses and accidents. However, the Corps’ estimate 

has limitations that raise questions about its reliability.



The first limitation is that the Corps’ analysis assumes that all prior 

accidents would be prevented by the jetty project and does not clearly 

control for factors that would be present with or without the jetty 

project. For example, Corps officials told us that under some weather 

conditions the inlet would be hazardous even with the recommended 20-

foot channel and dual jetties in place. Further, factors the Corps did 

not control for include changes in type of vessel traffic, operator 

experience, and vessel safety technology, all of which will continue to 

play a role in the number of accidents in the inlet, with or without 

the jetty project. For example, as mentioned earlier, the number of 

trips by trawlers between 1999 and 2001 is 85 percent less than the 

number of trips taken in the mid-1980s, and the Corps’ analysis does 

not reflect this change.



Second, the Corps estimate of $160,000 in annualized benefits from 

reduced vessel losses is based on outdated data, some of which are 

incorrect and some of which we could not verify. The GDM states that 

the Corps’ estimates of vessel losses and damages evolved from prior 

studies and the analyses of two consultants’ reports. With regard to 

vessel losses, a consultant’s report completed in 1987attributed the 

loss of 21 vessels between 1961 and 1986 to conditions in Oregon 

Inlet.[Footnote 30] The Corps used this information to estimate vessel 

losses in its 1990 economic analysis.[Footnote 31] Subsequently, a 1995 

consultant’s report estimated that the jetty project would prevent the 

loss of 14 vessels during the 50-year life of the project.[Footnote 32] 

This report updated data in prior studies, including the 1990 economic 

update by the Corps, and made adjustments because of reductions in the 

number of large fishing vessels using the inlet. However, unlike the 

1987 consultant’s report, the 1995 consultant’s report did not identify 

specific vessels lost or explain its basis for arriving at its estimate 

of 14 vessels. For its 2001 economic analysis, the Corps relied on the 

1995 consultant’s report that assumed the 20-foot channel and dual 

jetties would prevent the estimated loss of 14 vessels.



We asked the Corps to provide us with the supporting documentation 

behind two previous economic analyses completed in 1987 and 1990. Corps 

officials could not provide this information, stating that the data may 

have been lost or discarded when the office relocated. The 1987 

consultant report did, however, list the names of the vessels lost 

between 1961 and 1986 that it attributed to conditions in Oregon Inlet. 

Accordingly, we asked the Coast Guard for any available accident 

investigation reports regarding these vessels. The Coast Guard had no 

records for 12 of the 21 vessels that the consultant report listed as 

lost. As shown in table 5, of the nine accident investigation reports 

we reviewed, six of the losses were probably attributable to inlet 

conditions. Of the three losses that we found not attributable to the 

inlet, two occurred at locations other than Oregon Inlet and one was 

caused by mechanical failure. Because we found that three of nine 

vessel losses--33 percent--were not attributable to the inlet, we have 

concerns about the overall accuracy of the data in the report. Since it 

is unclear how information from the Kearney/Centaur report was used in 

updating the estimates of vessel losses for the Horizon Group report 

and the estimates of vessel losses in Corps’ latest economic analysis, 

we cannot determine the exact impact of the errors from the 1987 report 

on the Corps’ estimate.



Table 5: Summary of Information in U.S. Coast Guard Investigation Files 

on Vessel Losses at Oregon Inlet, 1961 through 1986:



Date of the accident: 10/13/77; Vessel name and identification number: 

M/V Tosco,; 505450; Location of the accident: The 7[TH] span south of 

the center of Bonner Bridge at Oregon Inlet.; Estimated value of lost 

vessel and contents: $100,000 for the vessel; $9,000 for the fish 

catch; Was the accident caused by Oregon Inlet conditions?: Yes; Value 

of the loss in constant 1997 dollars: $246,830.



Date of the accident: 11/01/77; Vessel name and identification number: 

F/V Miss Chievious Too, 582529; Location of the accident: Not specific, 

assumed to occur in Oregon Inlet or Pamlico Sound as the vessel was 

entering to find safe moorage.; Estimated value of lost vessel and 

contents: $40,000 for the vessel; Was the accident caused by Oregon 

Inlet conditions?: Yes; Value of the loss in constant 1997 dollars: 

$90,580.



Date of the accident: 02/09/79; Vessel name and identification number: 

F/V Dolphin, 258728; Location of the accident: The vessel sank in the 

Atlantic Ocean 9 miles southeast of Hatteras Inlet.; Estimated value of 

lost vessel and contents: $40,000 for the vessel; $2,000 for the fish 

catch; Was the accident caused by Oregon Inlet conditions?: No. The 

accident did not occur in Oregon Inlet.; Value of the loss in constant 

1997 dollars: [A].



Date of the accident: 08/25/79; Vessel name and identification number: 

F/V Ole Ugly, 265219; Location of the accident: After departing through 

Ocracoke Inlet, the vessel sank in the Atlantic Ocean.; Estimated value 

of lost vessel and contents: $250,000 for the vessel; Was the accident 

caused by Oregon Inlet conditions?: No. The accident did not occur in 

Oregon Inlet.; Value of the loss in constant 1997 dollars: [A].



Date of the accident: 12/31/81; Vessel name and identification number: 

F/V Coral Breeze, 543963; Location of the accident: At Oregon Inlet’s 

ocean bar.; Estimated value of lost vessel and contents: $170,000 for 

the vessel; $6,500 for the fish catch; Was the accident caused by 

Oregon Inlet conditions?: Yes; Value of the loss in constant 1997 

dollars: $288,493.



Date of the accident: 12/07/81; Vessel name and identification number: 

F/V Lady Phyllis, 618355; Location of the accident: The vessel hit the 

Bonner Bridge.; Estimated value of lost vessel and contents: $4,000 for 

the vessel; Was the accident caused by Oregon Inlet conditions?: No. 

Inlet conditions were calm. Incident was caused by mechanical failure.; 

Value of the loss in constant 1997 dollars: [A].



Date of the accident: 12/12/82; Vessel name and identification number: 

F/V Lois Joyce, 605933; Location of the accident: In the Oregon Inlet 

channel 150 feet outside buoy number 4.; Estimated value of lost vessel 

and contents: $850,000 for the vessel; Was the accident caused by 

Oregon Inlet conditions?: Yes; Value of the loss in constant 1997 

dollars: $1,307,894.



Date of the accident: 12/04/85; Vessel name and identification number: 

F/V Elizabeth Christine, 277218; Location of the accident: Within 

Oregon Inlet longitude and latitude coordinates.; Estimated value of 

lost vessel and contents: $150,000 for the vessel; Was the accident 

caused by Oregon Inlet conditions?: Yes; Value of the loss in constant 

1997 dollars: $207,526.



Date of the accident: 06/22/86; Vessel name and identification number: 

F/V Marlina, 249132; Location of the accident: Within Oregon Inlet 

longitude and latitude coordinates.; Estimated value of lost vessel and 

contents: $35,000 for the vessel; Was the accident caused by Oregon 

Inlet conditions?: Yes; Value of the loss in constant 1997 dollars: 

$47,374.



Date of the accident: Total; Value of the loss in constant 1997 

dollars: $2,188,697.



[A] Not calculated because the accident was not caused by Oregon Inlet 

conditions.



Source: Case files retrieved by Marine Casualty Investigation Division 

and printouts of electronic marine casualty reports from the Data 

Administration Division, U.S. Coast Guard.



[End of table]



Moreover, based on our review of more current Coast Guard records, from 

1986 through 2001, we identified the loss of four vessels that were 

likely attributable to inlet conditions. These are listed in table 6. 

Therefore, based on our review of the Coast Guard reports that were 

located on past cases and by updating this data using more current 

records, we identified 10 vessel losses that occurred because of inlet 

conditions between 1977 and 2001. The total value of these 10 vessels 

is about $2.4 million, or roughly $96,000 per year over that 24-year 

period, which is 40 percent less than the Corps’ estimate of $160,000 

per year in annualized benefits.[Footnote 33]



Table 6: Listing of Vessel Losses and Deaths Attributed to Conditions 

at Oregon Inlet, June 28, 1986, through November 27, 2001:



Date of the incident: 01/13/89; Vessel name and/or identification 

number: NC8559AS; Type of vessel: Fishing; Vessel length: 30; Number of 

deaths: 0; Value of the loss reported: $30,500; Value of the loss in 

constant 1997 dollars: $37,341.



Date of the incident: 12/30/92; Vessel name and/or identification 

number: High Liner, D620483; Type of vessel: Fishing; Vessel length: 

28; Number of deaths: 0; Value of the loss reported: $50,320; Value of 

the loss in constant 1997 dollars: $55,855.



Date of the incident: 11/20/96; Vessel name and/or identification 

number: NC9186BK; Type of vessel: Recreational; Vessel length: 17; 

Number of deaths: 1; Value of the loss reported: 0; Value of the loss 

in constant 1997 dollars: 0.



Date of the incident: 05/06/00; Vessel name and/or identification 

number: Little Fly Fisherman, D287083; Type of vessel: Recreational; 

Vessel length: 40; Number of deaths: 0; Value of the loss reported: 

$130,000; Value of the loss in constant 1997 dollars: $123,821.



Date of the incident: 11/27/01[A]; Vessel name and/or identification 

number: NC9367DA; Type of vessel: Recreational; Vessel length: 16; 

Number of deaths: 1; Value of the loss reported: $8,500; Value of the 

loss in constant 1997 dollars: $7,934.



Date of the incident: Total; Vessel name and/or identification number: 

[Empty]; Type of vessel: [Empty]; Vessel length: [Empty]; Number of 

deaths: 2; Value of the loss reported: $219,320; Value of the loss in 

constant 1997 dollars: $224,951.



[A] While we reviewed U.S. Coast Guard records from June 28, 1986, 

through September 30, 2001, we included a fatal accident that occurred 

in November 2001.



Source: U.S. Coast Guard and North Carolina Wildlife Resources 

Commission.



[End of table]



The third limitation we identified to the Corps’ analysis involves the 

estimated annualized benefits of $392,000 in reduced vessel damages if 

the jetty project is built. Again, the Corps relied partly on data 

developed in the 1987 consultant’s study.[Footnote 34] To estimate the 

value of damages to vessels, the consultant interviewed vessel captains 

and marine repair yards and determined that the average annual damage 

per vessel due to inlet conditions was about $7,000. The Corps then 

multiplied this figure by the number of full-time commercial fishing 

vessels that it estimated were using the inlet, which it determined to 

be 56 full-time vessels, to arrive at $392,000 in reduced vessel 

damages. In its estimate, the Corps assumed that all trawlers using the 

inlet would sustain damages each year. The Corps could not provide 

documentation for this assumption. In contrast, as shown in table 7, 

our analysis of Coast Guard data over this period showed that only 10 

commercial fishing vessels 55 feet and longer reported damages, which 

totaled on average about $1,700 per year.



Table 7: Listing of Vessel Damages Attributed to Conditions at Oregon 

Inlet between June 28, 1986, and September 30, 2001:



Date of the incident: 07/04/86; Vessel name and/or identification 

number: Northerly Island, D664129; Type of vessel: Dredge; Vessel 

length: 194; Number of injuries: 0; Value of the damage reported: 

$75,000; Value of the damage in constant 1997 dollars: $101,516.



Date of the incident: 10/14/86; Vessel name and/or identification 

number: Capt. Weddell, D654888; Type of vessel: Fishing; Vessel length: 

74; Number of injuries: 0; Value of the damage reported: 0; Value of 

the damage in constant 1997 dollars: 0.



Date of the incident: 06/12/87; Vessel name and/or identification 

number: God’s Mercy, D561112; Type of vessel: Fishing; Vessel length: 

77; Number of injuries: 0; Value of the damage reported: 0; Value of 

the damage in constant 1997 dollars: 0.



Date of the incident: 04/04/88; Vessel name and/or identification 

number: Schweizer, CG010063; Type of vessel: Dredge; Vessel length: 

133; Number of injuries: 0; Value of the damage reported: $40,000; 

Value of the damage in constant 1997 dollars: $50,832.



Date of the incident: 05/05/88; Vessel name and/or identification 

number: Kokina, D585863; Type of vessel: Fishing; Vessel length: 72; 

Number of injuries: 0; Value of the damage reported: 0; Value of the 

damage in constant 1997 dollars: 0.



Date of the incident: 05/26/88; Vessel name and/or identification 

number: Boss Lady, D505741; Type of vessel: Fishing; Vessel length: 82; 

Number of injuries: 0; Value of the damage reported: $15,000; Value of 

the damage in constant 1997 dollars: $19,062.



Date of the incident: 04/15/89; Vessel name and/or identification 

number: Mermentau, D643740; Type of vessel: Dredge; Vessel length: 197; 

Number of injuries: 0; Value of the damage reported: 0; Value of the 

damage in constant 1997 dollars: 0.



Date of the incident: 10/26/90; Vessel name and/or identification 

number: Northerly Island, D664129; Type of vessel: Dredge; Vessel 

length: 194; Number of injuries: 0; Value of the damage reported: 

$6,500,000; Value of the damage in constant 1997 dollars: $7,658,772.



Date of the incident: 09/07/92; Vessel name and/or identification 

number: Uncloudy Day, D950979; Type of vessel: Fishing; Vessel length: 

55; Number of injuries: 0; Value of the damage reported: $3,000; Value 

of the damage in constant 1997 dollars: $3,330.



Date of the incident: 01/13/94; Vessel name and/or identification 

number: Louise, MS4131AP; Type of vessel: Fishing; Vessel length: NA; 

Number of injuries: 0; Value of the damage reported: 0; Value of the 

damage in constant 1997 dollars: 0.



Date of the incident: 04/27/94; Vessel name and/or identification 

number: Lucky Thirteen, D606275; Type of vessel: Fishing; Vessel 

length: 65; Number of injuries: 0; Value of the damage reported: 0; 

Value of the damage in constant 1997 dollars: 0.



Date of the incident: 07/22/94; Vessel name and/or identification 

number: Gallant Fox, D567254; Type of vessel: Fishing; Vessel length: 

72; Number of injuries: 0; Value of the damage reported: $1,000; Value 

of the damage in constant 1997 dollars: $1,062.



Date of the incident: 04/07/95; Vessel name and/or identification 

number: Portugal, D608405; Type of vessel: Fishing; Vessel length: 74; 

Number of injuries: 0; Value of the damage reported: 0; Value of the 

damage in constant 1997 dollars: 0.



Date of the incident: 10/08/95; Vessel name and/or identification 

number: Hoosier State, D581970; Type of vessel: Tug; Vessel length: 43; 

Number of injuries: 0; Value of the damage reported: 0; Value of the 

damage in constant 1997 dollars: 0.



Date of the incident: 12/07/95; Vessel name and/or identification 

number: Clayton Reed, D683286; Type of vessel: Fishing; Vessel length: 

45; Number of injuries: 0; Value of the damage reported: $6,000; Value 

of the damage in constant 1997 dollars: $6,236.



Date of the incident: 12/11/95; Vessel name and/or identification 

number: Atchafalaya, D630005; Type of vessel: Dredge; Vessel length: 

197; Number of injuries: 0; Value of the damage reported: 0; Value of 

the damage in constant 1997 dollars: 0.



Date of the incident: 06/03/97; Vessel name and/or identification 

number: Hooker, D592896; Type of vessel: Passenger; Vessel length: 46; 

Number of injuries: 1; Value of the damage reported: 0; Value of the 

damage in constant 1997 dollars: 0.



Date of the incident: 11/02/99; Vessel name and/or identification 

number: War Cry, D614462; Type of vessel: Recreational; Vessel length: 

76; Number of injuries: 0; Value of the damage reported: 0; Value of 

the damage in constant 1997 dollars: 0.



Date of the incident: 12/31/99; Vessel name and/or identification 

number: Capt. Malc, D607993; Type of vessel: Fishing; Vessel length: 

81; Number of injuries: 0; Value of the damage reported: $300; Value of 

the damage in constant 1997 dollars: $292.



Date of the incident: 02/22/00; Vessel name and/or identification 

number: Adrien Rose, D538410; Type of vessel: Fishing; Vessel length: 

46; Number of injuries: 0; Value of the damage reported: 0; Value of 

the damage in constant 1997 dollars: 0.



Date of the incident: 02/20/01; Vessel name and/or identification 

number: Snoopy II, D563195; Type of vessel: Fishing; Vessel length: 52; 

Number of injuries: 0; Value of the damage reported: $500; Value of the 

damage in constant 1997 dollars: $467.



Date of the incident: 05/30/01; Vessel name and/or identification 

number: C-Venture, D539167; Type of vessel: Fishing; Vessel length: 73; 

Number of injuries: 0; Value of the damage reported: $1,500; Value of 

the damage in constant 1997 dollars: $1,400.



Date of the incident: Total; Average loss per year (15 years); Value of 

the damage reported: $6,642,300; $301,923; Value of the damage in 

constant 1997 dollars: $7,842,969; $356,499.



Date of the incident: Total for 10 fishing vessels 55’ and over; 

Average loss per year (15 years); Value of the damage reported: 

$20,800; $1,387; Value of the damage in constant 1997 dollars: $25,146; 

$1,676.



Source: Electronic marine casualty reports from the Data Administration 

Division, U.S. Coast Guard.



[End of table]



Finally, the Corps’ analysis assessed damages to trawlers only and 

excluded potential damages to other vessels. Our analysis of Coast 

Guard records on reported incidents for all vessels from 1986 through 

2001 showed that conditions in Oregon Inlet caused damages totaling 

about $7.8 million, or about $520,000 per year over that 15-year 

period, which is 25 percent more than the Corps estimate of $392,000 

per year in annualized:



benefits.[Footnote 35] However, most of the total damages--$7.7 

million--were attributable to one accident involving a dredge, which, 

torn from its anchor by a storm, struck and caused the collapse of a 

part of the bridge that spans Oregon Inlet. If the dredge accident were 

removed from the calculation, the average damages over the 15-year 

period would be about $12,000 per year, or nearly 98 percent less than 

the Corps’ estimate.



Although we could verify some of the earlier estimates of vessel losses 

and damages and were able to provide more current data from a review of 

accident reports, the extent to which past deaths and vessel losses and 

damages might have been prevented by the Corps’ proposed jetty project 

is not known. Consequently, we did not revise the Corps’ estimate of 

benefits to include this more recent data.



Corps Did Not Clearly Explain How It Derived Its Estimate Of Lives That 

Might Be Saved by the Proposed Jetty Project:



In addition to not incorporating the economic value of the lives that 

might be saved by the proposed jetty project in its estimate of 

benefits, the Corps did not clearly explain how it estimated that 14 

lives might be saved over the 50-year life of the project. Corps’ 

Wilmington District Office officials told us that they used their own 

studies and the 1987 Kearney/Centaur report as the basis for estimating 

that 14 lives might be saved by the project. The Kearney/Centaur report 

identified that 20 lives were lost with an associated loss of 21 

vessels in Oregon Inlet from 1961 through 1986. We attempted to get 

data from the Corps that would document the 20 lost lives, but the 

Corps had not retained the supporting documentation for the Kearney/

Centaur report. As a result, we asked the Coast Guard to provide any 

accident reports that it had relative to the vessel losses and 20 lost 

lives identified in the Kearney/Centaur report. The Coast Guard could 

only provide information on nine of the lost vessels. Based on our 

review of the nine cases, we found that the Kearney/Centaur report 

excluded four deaths resulting from a 1977 vessel loss even though 

information in the Coast Guard accident report implicated inlet 

conditions in the loss. In addition, we found that one death included 

in the Kearney/Centaur report did not occur in Oregon Inlet. Moreover, 

based on our review of more current Coast Guard records from 1986 

through 2001 (see table 6 above), we identified two deaths--one in 1996 

and the other in 2001--that were attributable to inlet conditions. Both 

of these accidents involved small recreational boats. Consequently, 

based on our review, we found that at least six deaths were 

attributable to conditions in Oregon Inlet over the 

25-year period from 1977 through 2001, which is slightly less than the 

Corps estimate over a comparable period. However, whether these 

accidental deaths would have been prevented by the jetty project is 

uncertain. As mentioned above, the Corps’ analysis assumed that all 

prior vessel accidents that included deaths would be prevented by the 

jetty project without clearly controlling for factors that would be 

present with or without the jetty project. For example, Corps officials 

told us that under some weather conditions the inlet would be hazardous 

even with the recommended 20-foot channel and dual jetties in place.



Corps Relied on Outdated Data Collected with Questionable Survey and 

Sampling Techniques to Estimate Recreational Benefits:



The Corps estimated that the jetty project alternative would generate 

about $3.4 million dollars in annualized benefits for recreational 

boaters by reducing high waves and sand accumulation in the ocean bar 

navigation channel, thus allowing for more trips. This estimate 

includes an estimated $2.8 million in benefits for private recreational 

boats, with the remaining benefits for anglers on charter and party 

boats. We could not verify the Corps’ estimates because it did not 

retain supporting documentation, and independently calculating the 

estimates would require an inordinate amount of time and resources. 

However, based on our review of the Corps’ approach and methodology 

used in developing the estimates, we have identified three limitations 

that raise questions about the reliability and usefulness of the 

estimated benefits.



First, the Corps’ original data collection effort, conducted in 1983, 

used a survey instrument that may have biased the boaters’ responses in 

favor of the jetty project. For example, to estimate the additional 

trips that private recreational boaters might be willing to take if the 

jetty project were constructed, the Corps mailed a survey to 3,876 

registered owners of recreational power and sail boats at least 19 feet 

long who were likely to have used Oregon Inlet in 1983. The Corps 

received 1,044 usable responses[Footnote 36] and from them concluded 

that private recreational boaters would increase their average annual 

use of the inlet from 8.59 trips through the Inlet per year to 19.34 

trips per year if the jetties were built. The cover letter accompanying 

the mail survey included the following introduction to the topic, 

stating that “despite 22 years of intensive maintenance dredging, the 

Corps has been able to maintain the channel depth only 25 percent of 

the time and has never been able to maintain the 400-foot channel 

width” and that “numerous groundings, vessel losses, personal injuries, 

and deaths have occurred.” In addition, the survey instrument asked 

respondents to estimate the number of days per year they “currently 

use” Oregon Inlet and the number of days per year they “would use 

Oregon Inlet if it were stabilized with dual jetties and a deeper, more 

reliable channel.” The wording implied that the channel would be safely 

passable all of the time if the jetty project were built, which is not 

the case. Corps officials acknowledge that even with the jetty project 

there will be periods when weather conditions will make the inlet 

impassable.



Concerning the estimated use of the inlet, a 1987 consultant’s report 

noted that some survey responses seemed too extreme to be credible. For 

example, on average, respondents indicated they currently used the 

inlet 11 days each year. However, a number of respondents indicated a 

substantially higher use, with the highest reported estimate being 250 

days per year. To address this concern in its most recent economic 

analysis, the Corps calculated new estimates using only responses that 

indicated a use of 60 days or less. This resulted in the Corps 

excluding 23 responses that were above this number. However, the 60-day 

threshold was arbitrary, and it neither accounts for the possibility 

that some responses above the threshold may be legitimate nor addresses 

the problem that responses below the threshold may have also been 

subject to biased wording. While the overall estimated benefits are 

lower than they would be if all responses were included, we could not 

determine the reasonableness of these estimates. The Corps does not 

believe the surveys contained bias. They said that the Office of 

Management and Budget (OMB) approved the surveys and that the wording 

“deeper, more reliable channel” would be an accurate description of the 

channel with the implementation of the jetty project. Both the 

Paperwork Reduction Act and OMB’s process for reviewing surveys have 

changed since 1983. However, the OMB official who currently reviews 

Corps surveys told us that the current OMB approval process does not 

ensure that a survey instrument is free from bias, although the 

reviewer may suggest changes if he or she detects bias, along with any 

other editorial comments. Because OMB does not keep records beyond 10 

years, we could not determine the nature and extent of OMB’s comments 

concerning the Corps’ 1983 surveys.



Second, the Corps’ 2001 economic analysis of recreational benefits 

relied on survey data from 1983 and 1984. These data are outdated and 

may not reflect the economic value that today’s boaters would place on 

any additional trips they would be able to take if the jetty project 

were built. The demand for recreational fishing is dependent upon 

factors such as the current cost (for example, expenses and time 

incurred in traveling to the site) and the current availability of 

substitute fishing sites and other recreational 

opportunities.[Footnote 37] For its most recent analysis, the Corps 

updated the original survey data by increasing the results by the rate 

of growth in regional tourism and visitation from 1984 through 1995. 

The Corps then used the updated survey data as a starting point for 

projecting recreational demand another 50 years into the future--the 

life of the jetty project--to 2051. However, changes in tourism and 

visitation primarily reflect changes in population rather than changes 

in relative prices or substitute recreational opportunities. 

Consequently, the reliability of the Corps’ recreational demand 

projections is questionable. Corps officials acknowledged that their 

recreational benefit estimates are based on outdated data but said they 

had not received funding to update the data. In addition, they believe 

that recreational activity has increased at Oregon Inlet and that using 

data that are more current would not change estimated recreational 

benefits of the jetty project. Nonetheless, the Corps does not have 

current data on the economic value that recreational boaters would 

attribute to the jetty project alternative to support its contention.



Third, in estimating the economic value of the additional fishing 

trips, the Corps used data collected from anglers on private boats and 

charter boats during three 1-week periods in August, September, and 

October of 1983. The Corps used these data to estimate that the average 

value of a fishing trip was $22.56 per person per day. However, both 

the number of fishing trips and the type of catch vary considerably 

over the year. The 3-month period during which the data were collected 

is the highest-use period for recreational fishing. The value of a 

fishing trip, according to those fishing in August, September, and 

October, may differ from the value assigned by those fishing during 

other months because the number of boats and anglers varies by season, 

as does the type of fish caught and the severity of weather and sand 

accumulation in the inlet. Therefore, since data were gathered only 

from anglers during the peak recreational season, the Corps’ estimate 

of the value of a fishing trip may not be a reasonable representation 

of the value of such a trip for the entire fishing season. Furthermore, 

there was no update of these data in the Corps’ most recent economic 

analysis. Corps officials said that since most fishing trips occur 

during the months of August, September, and October, values for those 

months would be weighted most heavily, even if data from additional 

months were collected, and that there was no reason to believe that 

trips in other months would be less valuable. For example, they said 

charter boat fishing rates are the same in other months as they are in 

the highest-use months. Nonetheless, the Corps did not incorporate the 

value of the additional trips that recreational anglers fishing in 

lower-use months might be willing to take if the proposed jetty project 

were built. The value of the additional trips during lower-use months 

could be lower or higher than the value in higher-use months for 

several reasons, including the type of fish that are available, the 

weather, and the particular preferences of the angler.



Corps’ Approach to Valuing Benefits Associated with Reduced Erosion Is 

Inconsistent with Federal Guidelines:



The Corps estimated that the proposed jetty project would yield about 

$1 million in annualized benefits by preventing the erosion of beaches 

to the north and south of Oregon Inlet. Because the protected land to 

the north of the inlet is part of the national seashore and to the 

south of the inlet is part of a national wildlife refuge, the benefits 

derived from the jetty project would be the recreational opportunities 

generated from the public use of the protected land. However, the Corps 

used valuation techniques that are not consistent with federal 

guidelines for valuing recreational benefits. As a result, the 

reliability of the Corps’ estimate of $1 million for erosion prevention 

is questionable and thus less useful because it does not reflect the 

value of the land as it is currently used for recreation and as 

wildlife habitat.



Federal guidance states that benefits arising from a project that 

generates recreational opportunities should be measured in terms of the 

willingness of users to pay for the recreational opportunity. For 

example, the fees users are willing to pay to visit a site and any 

unpaid value[Footnote 38] enjoyed by the recreationist can be used to 

measure benefits. Although the Corps’ economic analysis states that the 

protected land could be valued in terms of its use for recreation, the 

Corps chose not to do so because an earlier consultant’s 

report[Footnote 39] found drawbacks with an approach that based the 

value of the land on the willingness to pay for recreational 

opportunities. In particular, the consultant’s report states that the 

land has a “uniqueness value” to the nation that would not be captured 

by techniques based on recreational visitation. As a result, the Corps 

did not use willingness to pay for recreational opportunities to 

calculate the value of the land. However, although the Corps agreed 

with the consultant’s argument, neither of the two valuation methods 

used by the Corps measured the uniqueness value of the land.[Footnote 

40]



The Corps used two different methods to derive two separate estimates 

of the benefits associated with the land that would be “protected” by 

the jetty project. Under one method, the Corps assumed that the jetty 

project would protect 5 acres of land per year from natural erosion. To 

determine the benefits, the Corps used the per-acre cost of bypassing 

sand (about $200,000) instead of the land’s value for recreational use. 

This method is inconsistent with federal guidelines, because the cost 

of preventing the erosion does not reflect willingness to pay for 

recreational use of the land. As a result, we could not determine 

whether the Corps’ estimate overstates or understates the value of the 

land for recreational use.



Under the second method, the Corps assumed that the jetty project would 

prevent erosion of 9.5 acres from nearby beaches each year, or roughly 

twice as much land as would be protected under the first method. 

District officials said they used the market value of local, private, 

undeveloped, non-erodible, oceanfront property as a way to reflect the 

land’s opportunity cost--the value of the land in its alternative best 

use--to initially value the protected land at about $426,000 per acre. 

However, because the protected land is erodible, the Corps reduced that 

value by 75 percent to make the land worth about $107,000 per acre. 

Under this method, the total value of the protected land was estimated 

to be roughly $1 million. However, Corps officials did not have 

documentation supporting the basis for reducing the value of the 

protected land by 75 percent. Moreover, since the land being protected 

is public land, it is not likely that the land will be sold for private 

use. Further, this approach does not consider the land’s use for 

recreation and is, therefore, inconsistent with federal guidelines for 

estimating recreational benefits. As a result, it fails to provide 

decision makers with reliable information regarding these potential 

benefits.



Corps officials said that their guidelines for conducting economic 

analysis allow the benefits of environmental protection projects to be 

judged equal to their costs, which is why the Corps used the cost of 

bypassing sand as the value of the land. Nonetheless, as mentioned 

above, the cost the Corps derived is not based on a measure of the 

willingness to pay, and, as a result, the extent to which the Corps’ 

estimated benefits approximate the value of the land for recreation 

purposes is not known.



The Corps Did Not Account for Risk and Uncertainty Associated with All 

Key Variables:



In developing its estimate of the benefits and costs of the jetty 

project alternative, the Corps did not fully account for the extent to 

which the net benefit estimates would be affected by the risk and 

uncertainty associated with potential measurement errors and 

variability in the underlying data and assumptions.[Footnote 41]



The economic analysis did account for some risk and uncertainty for 

some variables. For example, in developing its estimate of the 

operating costs that trawlers would save in harvesting fish if the 

jetty project were built, the Corps adjusted its estimates to reflect 

the year-to-year variability in fish populations. In addition, in 

developing its estimate of the cost to construct the jetty project and 

operate the sand bypassing system, the Corps increased its estimate by 

about 15 percent to account for unforeseen events that might increase 

construction costs. The Corps also included additional costs for sand 

bypassing to ensure that neighboring beaches do not erode at a greater 

rate than anticipated.



However, the Corps did not assess the effect of risk and uncertainty 

for other key data and assumptions on the net benefit estimates. For 

example, the Corps used single or “point” estimates for the amount of 

sand estimated to pass over the weir; the trips and operating cost 

savings for commercial fishing vessels; the additional trips that 

recreational boaters might take; the extent to which the jetty project 

might prevent vessel losses, damages, and accidental deaths; and the 

amount of dredging that might be required in the interior channels even 

with the proposed jetty project in place. For example, the amount of 

sand that is expected to pass over the weir and be used to reduce 

erosion on neighboring beaches is subject to some uncertainty because 

of errors inherent in modeling sand transport as well as variability in 

the frequency of storms and in ocean currents. By not fully assessing 

the effect of uncertainty, a decision maker might not be aware of the 

extent to which the net benefit estimates might change if the 

underlying assumptions deviate from the values assumed by the Corps.



[End of section]



Appendix V: Comparison of the Proposed Oregon Inlet Jetty Project to 

Similar Completed Jetty Projects:



Table 8 compares key characteristics of the proposed Oregon Inlet jetty 

project to other similar jetty projects located on coastal inlets of 

the Atlantic Ocean and Gulf Coast of the United States.



Table 8: Key Characteristics of the Proposed Oregon Inlet Jetty Project 

and Similar Completed Jetty Projects:



Key Characteristics:: Number of jetties; Proposed for Oregon Inlet, NC: 

2; Murrells Inlet, SC: 2; Colorado River, TX: 2; Ponce DeLeon, FL: 2; 

St. Lucie, FL: 2; Perdido Pass, AL: 2; East Pass, FL: 2; Rudee, VA: 2; 

Masonboro, NC: 2.



Key Characteristics:: Location of first jetty; Proposed for Oregon 

Inlet, NC: North side of inlet; Murrells Inlet, SC: North side of 

inlet; Colorado River, TX: East side of inlet; Ponce DeLeon, FL: North 

side of inlet; St. Lucie, FL: North side of inlet; Perdido Pass, AL: 

East side of inlet; East Pass, FL: East side of inlet; Rudee, VA: North 

side of inlet; Masonboro, NC: North side of inlet.



Key Characteristics:: Year completed; Proposed for Oregon Inlet, NC: 

Proposed; Murrells Inlet, SC: 1979; Colorado River, TX: 1990; Ponce 

DeLeon, FL: 1971; St. Lucie, FL: 1982; Perdido Pass, AL: 1969; East 

Pass, FL: 1969; Rudee, VA: 1968; Masonboro, NC: 1966.



Key Characteristics:: Length in feet; Proposed for Oregon Inlet, NC: 

10,020; Murrells Inlet, SC: 3,455; Colorado River, TX: 3,500; Ponce 

DeLeon, FL: 4,200; St. Lucie, FL: 3,975; Perdido Pass, AL: 1,800; East 

Pass, FL: 1,220; Rudee, VA: 765; Masonboro, NC: 3,650.



Key Characteristics:: Location of second jetty; Proposed for Oregon 

Inlet, NC: South side of inlet; Murrells Inlet, SC: South side of 

inlet; Colorado River, TX: West side of inlet; Ponce DeLeon, FL: South 

side of inlet; St. Lucie, FL: South side of inlet; Perdido Pass, AL: 

West side of inlet; East Pass, FL: West side of inlet; Rudee, VA: South 

side of inlet; Masonboro, NC: South side of inlet.



Key Characteristics:: Year completed; Proposed for Oregon Inlet, NC: 

Proposed; Murrells Inlet, SC: 1980; Colorado River, TX: 1990; Ponce 

DeLeon, FL: 1969; St. Lucie, FL: 1982; Perdido Pass, AL: 1969; East 

Pass, FL: 1969; Rudee, VA: 1968; Masonboro, NC: 1980.



Key Characteristics:: Length in feet; Proposed for Oregon Inlet, NC: 

6,575; Murrells Inlet, SC: 3,319; Colorado River, TX: 2,900; Ponce 

DeLeon, FL: 2,700; St. Lucie, FL: 1,000; Perdido Pass, AL: 1,800; East 

Pass, FL: 3,400; Rudee, VA: 815; Masonboro, NC: 3,450.



Key Characteristics:: Typical tidal prism[A] (in millions of cubic 

feet); Proposed for Oregon Inlet, NC: 2,810.0; Murrells Inlet, SC: 

580.0; Colorado River, TX: 1.7; Ponce DeLeon, FL: 509.0; St. Lucie, FL: 

5.2; Perdido Pass, AL: 435.6; East Pass, FL: 1,620.0; Rudee, VA: 16.6; 

Masonboro, NC: 680.0.



Key Characteristics:: Sediment transport, in cubic yards, as viewed 

from land.



Key Characteristics:: Left; Proposed for Oregon Inlet, NC: 611,000; 

Murrells Inlet, SC: 54,000; Colorado River, TX: 0; Ponce DeLeon, FL: 

348,000; St. Lucie, FL: 72,600; Perdido Pass, AL: 130,000; East Pass, 

FL: 65,000; Rudee, VA: 378,000; Masonboro, NC: 200,000.



Key Characteristics:: Right; Proposed for Oregon Inlet, NC: 1,473,000; 

Murrells Inlet, SC: 186,000; Colorado River, TX: 600,000; Ponce DeLeon, 

FL: 363,000; St. Lucie, FL: 130,000; Perdido Pass, AL: 65,000; East 

Pass, FL: 130,000; Rudee, VA: 93,000; Masonboro, NC: 500,000.



Key Characteristics:: Net; Proposed for Oregon Inlet, NC: 862,000; 

Murrells Inlet, SC: 132,000; Colorado River, TX: 600,000; Ponce DeLeon, 

FL: 15,000; St. Lucie, FL: 57,400; Perdido Pass, AL: 65,000; East Pass, 

FL: 65,000; Rudee, VA: 285,000; Masonboro, NC: 300,000.



Key Characteristics:: Weir location; Proposed for Oregon Inlet, NC: 

North jetty; Murrells Inlet, SC: North jetty; Colorado River, TX: East 

jetty; Ponce DeLeon, FL: North jetty; St. Lucie, FL: North jetty; 

Perdido Pass, AL: East jetty; East Pass, FL: West jetty; Rudee, VA: 

South jetty; Masonboro, NC: North jetty.



Key Characteristics:: Weir length in feet; Proposed for Oregon Inlet, 

NC: 1,000; Murrells Inlet, SC: 1,880; Colorado River, TX: 1,000; Ponce 

DeLeon, FL: Formerly 1,800; St. Lucie, FL: 900; Perdido Pass, AL: 

1,000; East Pass, FL: Formerly 1,000; Rudee, VA: 475; Masonboro, NC: 

1,000.



Key Characteristics:: Weir elevation in feet above mean low water; 

Proposed for Oregon Inlet, NC: 1.5; Murrells Inlet, SC: 2.2; Colorado 

River, TX: 0.74; Ponce DeLeon, FL: Closed; St. Lucie, FL: 0; Perdido 

Pass, AL: -0.5; East Pass, FL: Closed; Rudee, VA: 2.15; Masonboro, NC: 

2.16.



Key Characteristics:: Left; Proposed for Oregon Inlet, NC: 611,000; 

Murrells Inlet, SC: 54,000; Colorado River, TX: 0; Ponce DeLeon, FL: 

348,000; St. Lucie, FL: 72,600; Perdido Pass, AL: 130,000; East Pass, 

FL: 65,000; Rudee, VA: 378,000; Masonboro, NC: 200,000.



Key Characteristics:: Right; Proposed for Oregon Inlet, NC: 1,473,000; 

Murrells Inlet, SC: 186,000; Colorado River, TX: 600,000; Ponce DeLeon, 

FL: 363,000; St. Lucie, FL: 130,000; Perdido Pass, AL: 65,000; East 

Pass, FL: 130,000; Rudee, VA: 93,000; Masonboro, NC: 500,000.



Key Characteristics:: After jetties, percentage of time channel less 

than authorized depth; Proposed for Oregon Inlet, NC: NA; Murrells 

Inlet, SC: 1; Colorado River, TX: 70; Ponce DeLeon, FL: 10 or less; St. 

Lucie, FL: 80; Perdido Pass, AL: 0; East Pass, FL: 20; Rudee, VA: 7 to 

8; Masonboro, NC: Less than 5.



[A] Tidal prism is the volume of water flowing in or out of an estuary 

between high and low tides.



Source: GAO interviews with officials responsible for the projects.



[End of section]



Appendix VI: Comments from the Department of the Army:



DEPARTMENT OF THE ARMY OFFICE OF THE ASSISTANT SECRETARY CIVIL WORKS 

108 ARMY PENTAGON:



WASHINGTON DC 20310-0108:



13 September 2002:



REPLY TO ATTENTION OF:



Mrs. Gary L. Jones Director:



Natural Resources and Environment U.S. General Accounting Office:



441 G Street, NW Washington, D. C. 20548:



Dear Mrs. Jones:



This is the Department of Defense (DoD) response to the General 

Accounting Office (GAO) draft report, GAO-02-803, OREGON INLET JETTY 

PROJECT: Environment and Economic Concerns Still Need to be Resolved, 

dated August 28, 2002, (GAO Code 360049).



We appreciate the opportunity to comment on GAO’s draft report as well 

as GAO’s cooperation in the clarification of issues by the Army. The 

report is important to the Department because it provides a current and 

independent assessment of the Oregon Inlet jetty project. It is 

responsive to the issues you were charged to address, specifically, (1) 

assess Federal efforts to maintain the ocean bar navigation channel in 

Oregon Inlet; (2) assess the extent to which the Corps 2001 economic 

analysis of the jetty project is useful for decision making; (3) 

provide information on the performance of similar jetty projects; (4) 

determine whether the Corps applied lessons learned from similar jetty 

projects in its design of the Oregon Inlet jetty project; and (5) 

identify and discuss concerns raised by the Departments of Commerce and 

Interior about development of the jetty project. Our comments are 

ordered to address these five topics.



(1) The GAO report accurately assesses Federal efforts to maintain a 

reliable navigation channel. We concur in the GAO finding that because 

of the inlet’s high-energy environment, dredging efforts have not 

provided a safe navigation channel and consequently loss of life,



vessel losses, and vessel damages will likely continue. It is also 

likely that the Coast Guard will continue to have difficulty 

maintaining navigation buoys. The average cost of dredging to maintain 

a 14-foot navigation channel from 1983-1994 was $4.1 million per year, 

but this provided a reliable channel only 23 percent of the time. After 

1994, the Corps spent about $2 million per year and maintained the 

channel depth about 15 percent of the time. Dredging has simply not 

been a reliable means of maintaining a safe channel.



(2) We believe that some differences in benefits result from 

differences in methodologies employed by the two agencies and a GAO 

auditing perspective versus a Corps project evaluation perspective. 

Since the Corps has not done any economic studies since 1999, it is 

difficult to evaluate GAO data that differs from data in the Corps 

study. Overall, the Corps agrees with GAO’s conclusions and 

recommendations that GAO was unable to determine whether the proposed 

jetty system is economically justified at this time and that a new 

economic analysis of the project is needed to decide whether to proceed 

with the project. While GAO was unable to assess the effects of all the 

changes to net benefits, GAO’s conclusions appear to be reasonable. 

Given the date of the Corps’ most recent economic analysis of the jetty 

project, the Corps’ own regulations require an economic reanalysis 

before starting construction.



(3) and (4) The GAO report provides information on similar jetty 

projects, such as those constructed with dual jetties and a low weir 

section. We concur in the GAO findings that the Corps applied lessons 

learned from construction of similar jetty projects and from internal 

Corps guidance. Masonboro Inlet in particular, which is located in the 

Wilmington District area and has performed as planned, provided 

valuable information on the need for dual jetties, the proper weir 

length, and the effect of erosion in this area. Finally, we concur that 

the information on eight similar jetty projects, their limitations, and 

the reasons for those limitations was useful. The information is 

helpful in maintaining our confidence that the Oregon Inlet project has 

adequate information on sand movement and should function as designed.



(5) The discussion of concerns of environmental resource agencies 

repeats concerns raised to the Feasibility Report, the Final 

Environmental Impact Statement, and in the referral to the Council on 

Environmental Quality (CEQ). Since the GAO report does not fully 

present the Corps position, we are enclosing the CEQ response package 

that addresses these issues for the record. We are especially pleased 

that GAO concurs with our recommendation that it would not be prudent 

to expend additional public funds to accomplish an economic reanalysis 

until CEQ favorably resolves the environmental concerns regarding the 

proposed jetty project and there are assurances from the Department of 

the Interior that permits will be granted. Despite 35 years of 

extensive studies, this project continues to show no progress, because 

of the environmental concerns and the reluctance of the Department of 

the Interior to provide approval for use of its lands to anchor any 

jetties. The Corps continues to believe that it has made project design 

changes and taken adequate mitigation measures to accommodate the 

environmental concerns of the Departments of Interior and Commerce. The 

Corps also believes that the jetty project is needed to allow large 

trawlers to navigate the inlet safely. We await CEQ’s findings on the 

environmental issues for this potential project.



Sincerely,



R. L. Brownlee Acting Assistant Secretary of the Army (Civil Works):



Signed by R. L. Brownlee:



[End of Section]



Appendix VII: Comments from the Department of the Interior:



United States Department of the Interior:



OFFICE OF THE SECRETARY Washington, D.C. 20240:



SEP 18 2002:



Ms. Gary L. Jones:



Director, Natural Resources and Environment U.S. General Accounting 

Office:



441 G Street, N.W. Washington, D.C. 20548:



Dear Ms. Jones:



Thank you for providing the Department of the Interior the opportunity 

to review and comment on the Draft Report entitled “OREGON INLET JETTY 

PROJECT: Environmental and Economic Concerns Still Need to Be Resolved” 

(GAO-02-803) dated August 28, 2002. In general, we agree with the 

findings in the report. The report is an objective and thorough 

analysis of a complicated project with over three decades of 

development. In particular, we concur with the finding that an analysis 

of incremental channel depths to update the most economically 

beneficial channel depth is warranted. The current commercial and 

recreational fishing fleets differ from those used in the original 

economic analyses for the project, and the project economics should 

accurately reflect the needs of the vessels currently using the inlet. 

We also agree with the recommendations that are directed to the Army 

Corps of Engineers, as they are consistent with Departmental position 

and comments over the past 10 years.



Although we concur with the findings of the draft report, we would like 

to offer a few points of clarification. The enclosure provides specific 

comments from the U.S. Fish and Wildlife Service and the National Park 

Service. We hope our comments will assist you in preparing the final 

report.



Sincerely,



Assistant Secretary for Fish and Wildlife and Parks:



Signed by the Assistant Secretary for Fish and Wildlife and Parks:



Enclosure:



U.S. General Accounting Office Draft Report “OREGON INLET JETTY 

PROJECT: Environmental and Economic Concerns Still Need to Be Resolved” 

GAO-02-803:



SPECIFIC COMMENTS:



The report’s statements concerning the U.S. Army Corps of Engineers’ 

current position are inconsistent. On one hand, the draft report states 

that the Corps is currently unwilling to spend additional public 

resources on analysis of the jetty project (see page 9, paragraph 2;



page 47, paragraph 2; and page 48, paragraph 1). On the other hand, the 

report describes the Corps as currently unwilling to spend additional 

public resources on analysis of alternatives for improving the safety 

and navigability of Oregon Inlet (see page 46, paragraph 2). The latter 

statement is much broader than those on pages 9, 47, and 48. Since the 

focus of this report is the jetty project rather than the overall 

management of Oregon Inlet, we suggest that the statement on page 46 

should be modified to be consistent with the others and address only 

the jetty project. We further suggest that the second paragraph on page 

46 should note that the Corps has not applied for Interior permits to 

construct the current dual jetty system.



The draft report notes that economic benefits may result from avoided 

accidental deaths at the proposed jettied inlet (see page 7, paragraph 

1; and page 29, paragraphs 1 and 2). While we concur that this factor 

was not included in the current economic justification for the proposed 

project, we note that the economic costs of potential increases in 

accidental deaths, vessel damage, and other injuries resulting from the 

dual jetty and sand bypassing system are not incorporated either. The 

report should recommend that any further analysis of this project 

should include both the potential benefits and the increased risks to 

human life and vessel safety resulting from the jetties.



It would also be helpful if the report included a definition of the 

terms “commercial vessel” and “recreational vessel,” since the report 

recommends that any further economic analysis of the project should be 

based on commercial fishing trip data (see page 26, paragraph 1).



The current statement regarding Interior’s concern of “depositing too 

much sand onto its land” (see page 8, paragraph 2) does not adequately 

summarize our concerns about the sand bypassing system. We recommend 

that this statement be modified to read, “Interior believes that the 

jetties will increase beach erosion, especially on the south side of 

the inlet, and that the project’s sand bypassing system could harm 

coastal habitat and wildlife by depositing large quantities of sand 

annually without allowing sufficient time for recovery of the 

ecosystem.” Similarly, the last sentence on page 8 that continues on 

page 9, would be more accurate if stated “The weir is also intended to 

facilitate the collection of sand, which the Corps plans to bypass to 

beaches on the south side of the inlet to address erosion and 

interrupted sediment transport.”:



The draft report states that the National Park Service manages the 

Federal lands located on the north side of Oregon Inlet (see page 8, 

paragraph 2; and page 41, paragraph 1). The NPS requests that these 

statements be expanded to clarify that Pea Island National Wildlife 

Refuge and lands south of the Refuge, which would be affected by 
project-

caused erosion and perpetual sand placements, are likewise within the 

boundaries of Cape Hatteras National Seashore.



The report would more accurately describe the purpose of the terminal 

groin on PINWR if it stated that, “The terminal groin is a rock 

structure that was completed in 1991 to protect the southern end of the 

Bonner Bridge” (see page 16, paragraph 2). Additionally, we suggest 

that the report recommend that any further economic analysis of the 

jetty project should take into account the anticipated expiration of 

the right-of-way permit for the terminal groin in 2010, possible 

removal of the terminal groin, and resulting increased costs of the 

jetty project. Also in this paragraph, we recommend replacing 

“adjacent” with “downdrift” in the second to last sentence.



Interior does not agree that the Masonboro Inlet jetties should be 

considered “performing as planned” (see pages 31 through 34). The 

original project design utilized one jetty, constructed in 1966. In 

1980, however, a second jetty was added to improve the performance of 

the managed inlet. Erosion of adjacent shorelines on Masonboro Island 

has also led to unanticipated supplemental dredging and beach fill 

activities to offset the interrupted sediment supply on Masonboro 

Island. Using one parameter to evaluate the overall performance of weir 

jetty projects, whether actual dredging needs are comparable to 

original project specifications, does not fully reflect the success or 

failure of those projects. We recommend that although Masonboro Inlet 

provides valuable lessons about weir jetties, the report should not 

characterize it as “performing as planned.” Further, we urge caution in 

making any direct comparison of the processes at Masonboro and Oregon 

Inlets since Masonboro Inlet experiences only one third of the sediment 

transport (see page 19, paragraph 1) and a lower wave energy climate 

than Oregon Inlet.



There are a few points worth clarifying in the section on pages 41 

through 43 that itemize Interior’s concerns with the project. In the 

first bulleted concern, the second and third sentences would be 

improved by reading “Interior stated that if the jetties are built, 

erosion and accretion patterns will be modified both south and north of 

the inlet, which in turn will increase overwash of the islands, 

especially during storms. This overwash will harm valuable wildlife 

habitat as well as plants and vegetation that provide food for 

waterfowl and other migratory birds.” The next sentence should replace 

the word “would” with “could” due to high levels of uncertainty 

regarding specific sediment transport volumes. We also recommend 

deletion of the phrase “the Bonner Bridge and” from the following 

sentence.



In the first bulleted point on page 42, we recommend that the 3’ 

sentence be amended to read “Interior stated that over the years 

frequent sand bypassing of large volumes might permanently eliminate 

these food sources and produce severe long-term adverse impacts on 

breeding, migrating and overwintering shorebirds.” The latter part of 

that sentence can serve as an independent statement starting with 

“Among these birds are the Great Lakes piping plover ...”. The last 

sentence of the bulleted point would be more accurate with the phrase 

“of incompatible sands” inserted after “perpetual sand placements.”:



The second bullet on page 42 describes Interior’s concerns about the 

performance of the weir. In particular, we remain concerned about the 

likely impacts of the Dare County Beaches Storm Damage Reduction 

Project, a large beach nourishment project immediately north of the 

Oregon Inlet jetties project area. While the draft report summarizes 

these concerns, the fifth sentence inaccurately attributes our concern 

over reduced sediment supply to aquatic habitats within Pamlico Sound 

to the offshore sand mining proposed for the beach nourishment project. 

In fact, the construction of the jetties and associated dredging and 

sand bypassing are the cause of our concern about reduced sediment 

supply to estuarine habitats, not the offshore sand mining. We 

recommend that this statement be moved to its own bullet as a separate 

Interior concern related to the jetties, separate from the Dare County 

beach nourishment project.



The NPS believes that the first complete bulleted point on page 43 does 

not fully describe the impact of the jetty project on public recreation 

at the Seashore. NPS therefore requests the addition of the following 

clause to the first sentence of this bullet point, “contrary to one of 

the legislated purposes of Cape Hatteras National Seashore.”:



The last sentence summarizing Interior’s concerns (pages 43 and 44) 

should be modified to more accurately describe the purpose of the PINWR 

by ending with the phrase “to manage, protect, and restore migratory 

birds and other wildlife.”:



We request several clarifications in the last paragraph on page 46 

before the Conclusions section. The fifth sentence would be more 

accurate if it read “FWS, likewise, issued the Corps a special use 

permit for disposal of dredge material on refuge lands during the 

Corps’ 2002 dredging effort.” The next sentence contains a 

typographical error, incorrectly referring to the Pea Island National 

Wildlife Reserve instead of the Pea Island National Wildlife Refuge. We 

recommend replacing the first two words (“FWS said”) at the start of 

the seventh sentence with the phrase:



“According to the NPS special use permit, the dredging operation....”:



[End of Section]



Appendix VIII: Comments from the Department of Commerce:



UNITED STATES DEPARTMENT OF COMMERCE National Oceanic and Atmospheric 

Administration CHIEF FINANCIAL OFFICER/CHIEF ADMINISTRATIVE OFFICER:



SEP 17 2002:



Ms. Gary Jones:



Director, Natural Resources and Environment:



United States General Accounting Office 441 G Street, N.W.



Washington, DC 20548:



Dear Ms. Jones:



Enclosed is the National Oceanic and Atmospheric Administration’s 

response to the draft report OREGON INLET JETTY PROJECT: Environmental 

and Economic Concerns Still Need to Be Resolved (GAO-02-803). We 

appreciate the opportunity to provide comments.



Sincerely,



Sonya G. Stewart:



Signed by Sonya G. Stewart:



Enclosure:



General comments:



The Department of Commerce and the National Oceanic and Atmospheric 

Administration (NOAA) commend the General Accounting Office’s (GAO) 

work in evaluating the issues surrounding the Oregon Inlet jetty 

construction project. Overall, we find that the report is thorough, and 

we concur with the determination that considerable revision of the 

economic and other analyses are needed before the feasibility and 

environmental effects of building jetties can be determined. We offer 

the following comments to clarify our position on some issues.



Specific comments:



Pages 8-9 “Results in brief’ and page 40 “Commerce and Interior remain 

concerned the Oregon Inlet project will harm the environment” The 

report states that the U. S. Army Corps of Engineers (COE) utilized 

lessons learned from other jetty projects by incorporating a weir into 

the design of the northern jetty to allow fish larvae to enter the 

sound. NOAA notes that the Corps originally found inclusion of a weir 

to be not acceptable based on considerable evidence indicating that 

such a structure could become blocked by sand. In such a situation, the 

weir would cease to function as a possible avenue for larvae movement, 

and also would cease to function as a sand bypass mechanism.



The concern about sand bypass is referenced as recently as 1995, 

wherein the Wilmington District’s Feature Design Memorandum for Sand 

Bypassing Management states: “The major concerns, particularly with the 

weir jetty plan, were the high rates of littoral (sand) transport that 

could occur during singular or multiple storm events, and the 

possibility of reversals in the net direction of littoral transport 

during any year. Also, the amount of material available for bypassing 

would be limited to that retained in the sediment trap. With respect to 

storms, sand transport could be so large that the weir would become 

‘landlocked,’ thus preventing the deposition of material in the 

sediment trap. . . “ Considering the importance of successful weir 

design and function, NOAA is extremely concerned over the uncertainties 

associated with this key component of the project.



NOAA notes that no direct evidence exists demonstrating the 

effectiveness of this or any other weir for achieving larval ingress. 

With specific reference to the proposed Oregon Inlet jetties, NOAA has 

advised the COE that the current weir design is unacceptable since it 

may not be properly positioned to allow larval ingress. More 

specifically, the proposed weir would be located adjacent to the 

shoreline and would extend offshore, joining the main jetty at a water 

depth of around 1 meter (m) below mean sea level (based on the adjusted 

depth contours following filet formation at the north jetty). Mean 

tidal ranges in the inlet are 0.6-0.7 m, thus, maximum water depths at 

the seaward end of the weir would be approximately 2 m. Because species 

composition, distribution, and abundance of larval fishes in such 
shallow 

water outside of inlets are largely undetermined, there is no basis for 
the 

presumption larvae will be transported across the weir.



Larval transport through the inlet is no minor issue. For numerous 

species born in offshore waters of the Atlantic Ocean, it is essential 

that they successfully migrate inshore from these offshore locations, 

through coastal inlets, and into estuaries where growth and development 

are possible. They cannot survive and mature in the open ocean. This 

group includes such notable species as summer flounder, shrimp, spot, 

and Atlantic croaker. Summer flounder is a key target species of 

commercial fishers for which the jetty project is intended to aid.



Oregon Inlet, due to its location, is a key entrance way to Albemarle 

Sound, Roanoke Sound, and northern Pamlico Sound for planktonic larval 

fish and invertebrates seeking essential developmental grounds in 

estuarine waters. The inlet, in many respects, is a last chance at 

survival for these organisms, since there is little probability that 

they would survive the journey to other coastal inlets located to the 

north and south of Oregon Inlet. Any reduction in the number of larvae 

that migrate through Oregon Inlet and into Albemarle Sound would not be 

offset by those entering from other inlets, since the hydrological 

connection between Albemarle Sound and other inlets is only minor. 

Also, according to North Carolina State University professor Dr. John 

Miller, Albemarle Sound is under-colonized by larvae. It is therefore 

likely that any reduction in larvae passed through Oregon Inlet would 

result in a comparable reduction in fishery production and harvest.



With regard to Page 8 (“Results in brief’), it should be noted that 

NOAA, in addition to the U.S. Fish and Wildlife Service and the 

National Park Service, is concerned that the jetties will significantly 

alter sand movement in the vicinity of Oregon Inlet and damage beaches, 

dunes, beds of submerged aquatic vegetation, salt marshes, shallow 

water habitats, and other aquatic sites and resources. NOAA also raised 

many or these concerns in referring the project to the President’s 

Council on Environmental Quality.



Pages 24-27: “Corps’ Economic analysis for the proposed Oregon Inlet 

Jetty Project has several limitations that undermine its usefulness” 

and pages 66-69: “Corps analysis of benefits to commercial fishing 

vessels relied on outdated trip data and excluded certain vessels” NOAA 

agrees with the GAO that using data from the 1980s to estimate 

potential benefits results in unrealistic estimates. In support of 

GAO’s findings, we note that since the 1980s, the size of the 

commercial fishing fleet has declined due to a vessel reduction program 

implemented by the South Atlantic Fishery Management Council. For this 

and other reasons, the foreseeable forecast for vessel numbers is one 

of fewer vessels rather than more.



Pages 7 28-29 69, and 75: Vessel safety and loss of life The GAO report 

appears to contain conflicting statements regarding inlet safety. Page 

28 states, “Corps estimates did not incorporate the economic value of 

accidental deaths that might be prevented by the proposed project.” 

This statement implies that the Corps’ estimate of 14 lives saved 

during 50 years is valid. However, on page 69 the report states the 

“Corps’ estimates of vessel losses and damages are based on unsupported 

assumptions and outdated data.”:



NOAA places the utmost value on human life, and fully supports the goal 

of safe and reliable navigation. However, we question the Corps’ 

estimates (as does the GAO draft report). We also note that the Corps 

did not assess the potential loss of life and related economic losses 

resulting from the presence of jetties. Based on information we 

examined, it is evident that jetties themselves may serve as a source 

of injury and accidental death. NOAA recommends that GAO consider 

revising these sections to address the potential dangers and economic 

costs that jetties present, and to specify that these considerations 

also require evaluation.



Page 32: “Two proiects are currently performing as planned” NOAA does 

not agree that the Masonboro Inlet Project is generally performing as 

planned. Although the GAO report (page 33) accurately describes the 

many problems associated with the Masonboro Inlet Project, the overall 

impression is that the jetties are operating as planned, which is 

clearly not the case. An abbreviated list of problems includes:



* The original project design called for a single jetty with a weir, to 

be located on the north side of the inlet. After currents undermined 

the jetty, it was determined that a second jetty would be needed.



* Predicted sand accumulation in the designated sand accumulation basin 

did not occur but instead, accumulated at the south end of Wrightsville 

Beach, causing difficulties for vessels entering the inlet.



* Erosion on Masonboro Island, a National Estuarine Research Reserve, 

and Wrightsville Beach, a high-use municipal beach, are at least 

accentuated by the project since periodic sand bypassing involves use 

of heavy equipment and causes considerable disturbance of human and 

natural uses of the beach.



Additionally, it should be noted that unexpected problems such as those 

realized at Masonboro Inlet could have far greater consequences at 

Oregon Inlet where sand volumes, wave energy, and the tidal prism far 

exceed those at Masonboro Inlet. Further, even though the dredging 

frequency may be less than anticipated at Masonboro and Murrells 

inlets, this is still reflective of miscalculation by the COE and 

should not be regarded as expected or planned performance, even though 

the outcome is beneficial in these instances.



Page 23: “Oregon inlet’s high energy environment and the Corns’ limited 

dredging have also reduced the Coast Guard’s ability to properly mark 

the ocean bar navigation channel” NOAA is pleased to note that the GAO 

addresses the current situation at Oregon Inlet relevant to placement 

of channel markers (buoys) by the U.S. Coast Guard. Given the location 

and natural conditions at this high energy inlet, it is likely that the 

location and depth of navigable waters will remain variable with or 

without jetties. However, as the GAO report implies, an improved 

dredging program could improve the ability of the Coast Guard to mark 

the channel, thereby improving navigation and safety at Oregon Inlet.



Page 15: Editorial comment Because it is describing a statutory 

definition in this case, NOAA recommends capitalizing the term 

“Essential Fish Habitat” in paragraph two.



Page 40: Editorial comment To be consistent with the rest of this 

section, NOAA suggests using bullets to separate the primary points in 

this section, i.e., habitat impacts, larval migration, and the safety 

record at Oregon Inlet.



Recommendations:



Page 48: GAO Recommendations NOAA supports the recommendations made by 

the GAO in this report.



[End of section]



Appendix IX: GAO Contact and Staff Acknowledgments:



GAO Contact:



(Ms.) Gary L. Jones (202) 512-3841:



Staff Acknowledgments:



In addition, Tim Guinane, Roy Judy, Ken McDowell, Cynthia Norris, Anne 

Rhodes-Kline, John Scott, Amy Webbink, and Jim Yeager made key 

contributions to this report.



FOOTNOTES



[1] P.L. 81-516, the River and Harbor Act of 1950, authorized the 

project, officially titled the Manteo (Shallowbag) Bay, North Carolina, 

project.



[2] All dollars in this report are 1997 dollars unless otherwise noted.



[3] P.L. 91-611, River and Harbor and Flood Control Acts of 1970.



[4] A weir is a section of a jetty that is lower than the rest of the 

structure. The weir is typically designed to allow water and sand to 

flow over it when the water level is greater than low tide.



[5] “The Outer Banks of North Carolina: Budget of Sediment and Inlet 

Dynamics Along a Migrating Barrier System” by Douglas L. Inman and 

Robert Dolan, Journal of Coastal Research, Spring 1989, 

Charlottesville, Virginia.



[6] The Herbert C. Bonner Bridge transverses Oregon Inlet and carries a 

highway that connects Bodie Island on the north side of the inlet to 

Pea Island on the south.



[7] Draft is the distance between the water level on a loaded vessel 

and its keel (bottom). The channel depth is determined by the loaded 

draft of a typical vessel as well as by factors including wave action 

and the extent to which the vessel “squats” in the water when it is 

underway due to propeller action.



[8] Identification of Essential Fish Habitat and requirements 

concerning its coordination and management are contained in the 

Magnuson-Stevens Fishery Conservation and Management Act, as amended by 

the Sustainable Fisheries Act of 1996 (P.L. 104-297).



[9] The Corps calculates the percentage by periodically surveying the 

depth of the channel. If any portion is less than the authorized depth 

of 14 feet, the channel is considered unavailable.



[10] The Corps’ estimate of sand movement is for the period 1956 

through 1975 as presented in its September 2001 GDM on the jetty 

project.



[11] A Reassessment of the Economic Feasibility of the Oregon Inlet 

Project, Kearney/Centaur, a Division of A.T. Kearney, Inc., prepared 

for the Corps of Engineers, July 1987.



[12] Data for 1999 through 2001 include landings made by both in-state 

and out-of-state vessels to seafood dealers in Dare, Hyde, Pamlico, and 

Beaufort Counties. According to state officials, trawlers using 

specified gear that land ocean-caught fish in these counties are 

assumed to pass through Oregon Inlet. Trips made by North Carolina 

vessels to land fish in other states are not included. Data for smaller 

vessels exclude fish that were landed in Hatteras (Dare County) because 

these landings are assumed to have been made using Hatteras Inlet



[13] Under the North Carolina trip ticket program, which was begun in 

1994, seafood dealers are required to report certain information about 

commercial fish landings, including the landing vessel’s 

identification, the species of fish caught, and the type of fishing 

gear used.



[14] The value of a statistical life is derived from studies of 

individuals’ willingness to pay for small reductions in the risk of 

dying. The estimate represents the value of the reduction in risk to a 

population and not the value of any identifiable individual.



[15] The $1.9 million represents the annualized amount, at 7.125 

percent interest, of dredging costs during the 4-year period required 

to construct the jetty project.



[16] The $6.8 million is the annualized value of the jetty project’s 

construction costs.



[17] The Corps made some computational errors in calculating the O&M 

costs for the current dredging program. Specifically, the Corps 

excluded $799,285 in costs that it had incurred dredging the ocean bar 

navigation channel in 1990, which it had inadvertently identified as an 

interior channel dredging expense. In addition, the Corps mistakenly 

double-counted $876,472 of costs incurred in 1991 to dredge the ocean 

bar navigation channel. We corrected for these two errors that 

essentially offset each other. Corps officials agreed with this 

correction.



[18] Even with the additional dredging, for one of the three projects 

the channel has been available less than the expected amount of time.



[19] A spit is a narrow point of land or sand mass extending from the 

shore.



[20] In 1992, the Secretary of the Interior issued two conditional 

permits to the Corps for use of Interior lands for jetty construction 

contingent on completion of project plans and environmental studies. 

These conditional permits were rescinded in 1993.



[21] Pea Island National Wildlife Refuge is within the boundary of the 

Cape Hatteras National Seashore.



[22] This panel was named for the first chairman, Dr. Douglas Inman, a 

coastal oceanographer with the Scripps Institution of Oceanography.



[23] The terminal groin at Oregon Inlet is a rock structure built 

perpendicular to the shoreline to protect the southern end of the 

Bonner Bridge by preventing the erosion of land on Pea Island, into 

which the bridge is anchored.



[24] Economic and Environmental Principles and Guidelines for Water and 

Related Land Resources Implementation Studies, U.S. Water Resources 

Council, 1983.



[25] Based on the state of North Carolina’s commercial fish landings 

trip ticket program.



[26] According to the state of North Carolina, the smaller vessels 

averaged about 35 feet in length and trawlers averaged about 73 feet. 

Vessels that are 35 feet in length have a draft of approximately 4 to 5 

feet.



[27] Since the Corps assumes no change in the fish harvest, the 

appropriate measure of savings is the marginal cost of the resources, 

such as fuel and oil, which would be saved by the proposed project.



[28] We used the period 1999 through 2001 because state officials said 

their vessel licensing data from before 1999 are less reliable. Vessel 

licenses were used to identify the county out of which each vessel 

operated in order to match the counties represented in the consultant’s 

1987 study. Nonetheless, regardless of the vessels’ operating ports, 

landings data by type of fishing gear also suggest trawler trips have 

declined relative to the consultant’s estimate from the mid-1980s. For 

example, for landings made in Dare, Hyde, Pamlico, and Beaufort 

Counties from 1994 through 1995, vessels using trawl gear landed about 

9.3 million pounds of fish on 561 trips, while vessels using gill nets 

landed about 16.3 million pounds of fish on about 5,200 trips 

(including trips via Hatteras Inlet). Vessels using gill nets are 

generally smaller than trawlers.



[29] For the adjusted analysis, we assumed no change in the fraction of 

total trips forced to other inlets or ports or in the average length of 

time a vessel is delayed. Using alternative values for these 

assumptions would change the estimated benefits.



[30] The Kearney/Centaur report, cited earlier.



[31] 1990 Update of 1984 Economic Analysis: Manteo (Shallowbag) Bay 

Project, North Carolina by the Corps of Engineers’ Wilmington District, 

July 1990.



[32] An Assessment of the Regional Economic Benefits of the Oregon 

Inlet Stabilization Project by the Horizon Planning Group, Wilmington, 

NC, January 1995.



[33] This calculation includes only the vessels listed as lost by the 

Corps consultant that we could verify and vessels identified as lost in 

our review of more recent Coast Guard records. Also, complete records 

were not available on state registered recreational boat accidents to 

determine how many were lost during the period we reviewed. The 1987 

consultant apparently did not review such records when identifying 

vessel losses.



[34] 1987 Kearney/Centaur study, cited earlier.



[35] Our estimate of damages is based on reported incidents and does 

not include any damages that were not reported to the Coast Guard.



[36] In 1983, the Corps reported using 1,094 responses and a response 

rate of 46 percent. In 2001, the Corps reported using 1,044 responses, 

stating that 176 surveys were undeliverable and 681 others were 

considered “not usable.” The Corps deemed a response “not usable” if 

the respondent no longer owned a boat, the boat was not used in the 

ocean, or because the information provided was “invalid” or appeared 

duplicative. The 2001 General Design Memorandum does not project the 

survey results to the entire population of respondents.



[37] The Corps used a “travel cost” model to estimate the value of the 

additional trips. This is a technique for approximating the value that 

recreationists would be willing to pay for the use of a site, based on 

factors such as the expenses and value of the time required to travel 

to the site.



[38] This unpaid value is called “consumers’ surplus” and is a standard 

measure of the net benefit derived from purchasing a good or service. 

Since the protected land is publicly provided and no fees are charged 

to enter the site, the value of the land can be estimated using 

indirect means such as the travel cost model.



[39] The Kearney/Centaur report, cited earlier.



[40] Economic techniques that measure total economic value could assess 

whether the acres saved would add to the uniqueness value of the 

national seashore and the wildlife refuge (use and non-use values).



[41] Federal guidance for water resources planning states that the 

effect of the risk and uncertainty should be examined. Risk reflects 

situations where potential outcomes can be described using reasonably 

well-known probability distributions. Uncertainty reflects situations 

where potential outcomes cannot be described in objectively known 

probability distributions.



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