Army Corps of Engineers: Additional Steps Needed for Review and Revision of Water Control Manuals
Published: 2016-07-26T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Corps owns and operates water resource projects, including more than 700 dams and their associated reservoirs across the country, for such purposes as flood control, hydropower, and water supply. To manage and operate each project, the Corps' districts use water control manuals to guide project operations. These manuals include water control plans that describe the policies and procedures for deciding how much water to release from reservoirs. However, many of the Corps' projects were built more than 50 years ago, and stakeholders have raised concerns that these manuals have not been revised to account for changing conditions.
The Water Resources Reform and Development Act of 2014 included a provision for GAO to study the Corps' reviews of project operations, including whether practices could better prepare the agency for extreme weather. This report (1) examines the extent to which the Corps has reviewed or revised selected water control manuals and (2) describes the Corps' efforts to improve its ability to respond to extreme weather. GAO reviewed the Corps' guidance on project operations; examined agency practices; and interviewed Corps officials from headquarters, all 8 divisions, and 15 districts—selected, in part, on regional differences in weather conditions.
section_title: What GAO Found
paragraphs: According to U.S. Army Corps of Engineers (Corps) officials, the agency conducts ongoing, informal reviews of selected water control manuals and has revised some of them, but the extent of the reviews and revisions is unclear because they are not documented or tracked, respectively. The Corps' engineer regulations state that water control manuals should be reviewed no less than every 10 years so that they can be revised as necessary. However, officials from all 15 districts GAO interviewed said they do not document informal reviews of water control manuals because they consider such reviews part of the daily routine of operating projects. The Corps does not have guidance, consistent with federal standards for internal control, on what activities constitute a review or how to document the results of reviews. Without such guidance, the Corps does not have reasonable assurance that it will consistently conduct reviews and document them to provide a means to retain organizational knowledge. The Corps' engineer regulations also state that water control manuals shall be revised as needed, but the extent to which manuals have been revised or need revision remains unknown because the Corps' divisions do not track consistent information about manuals. For example, based on GAO's review of the Corps' documents, one of the eight divisions tracked whether the water control plans in its water control manuals reflected actual operations of a project, but the remaining seven did not. While the Corps has revised certain water control manuals as called for by its regulations, district officials GAO interviewed said additional manuals need revision. However, the Corps does not track consistent information on manuals needing revision, in accordance with federal internal control standards. Without tracking which manuals need revision, it is difficult for the Corps to know the universe of projects that may not be operating in a way that reflects current conditions as called for in the Corps' engineer regulations.
The Corps has efforts under way to improve its ability to respond to extreme weather, including developing a strategy to revise drought contingency plans and studying the use of forecasting to make decisions on project operations. To better respond to drought, the Corps is developing a strategy to analyze drought contingency plans in its water control manuals to account for a changing climate. As of May 2016, the Corps was conducting, as a pilot, updates of five projects' drought contingency plans to help test methods and tools for future use in other plans. The Corps is also studying the use of forecasting tools to improve water supply and flood control operations at two projects in California by evaluating if they can retain storm water for future supply as long as the retained water can safely be released, if necessary, prior to the next storm. Knowledgeable stakeholders GAO interviewed said it is important for the Corps to consider forecast-based operations at its projects to help ensure efficient operations and to be able to respond to changing patterns of precipitation. Corps officials said the agency may consider doing so once the two California projects are completed in 2017.
section_title: What GAO Recommends
paragraphs: GAO recommends that the Corps develop guidance on what constitutes a water control manual's review and how to document it and track which manuals need revision. The agency concurred with the recommendations.

section_title: Letter
paragraphs: The U.S. Army Corps of Engineers (Corps) is the world’s largest public  engineering agency, with water resources projects across the United  States, including more than 700 dams that it owns and operates for a  variety of purposes including navigation, flood control, irrigation,  hydropower, water supply, recreation, and fish and wildlife conservation.  However, much of the Corps’ infrastructure for these dams and their  associated reservoirs was built more than 50 years ago. To manage and  operate each water resources project, the Corps’ 38 district offices  develop water control manuals to guide project operations. These  manuals describe the project’s dams, reservoirs, and any affected rivers;  historic floods and storms in the project area; and data from other  agencies, such as the Department of Commerce’s National Oceanic and  Atmospheric Administration (NOAA) and the Department of the Interior’s  U.S. Geological Survey (USGS), that the Corps uses in operating the  projects. The manuals also, among other things, describe methods for  forecasting the amount of runoff flowing to the dams’ reservoirs,  document policies and procedures for deciding how much water to  release from the reservoirs, and generally have an associated drought  contingency plan that provides guidance for district actions in response to  periods of water shortages. Stakeholders, such as local governments and  advocacy groups, have raised concerns that some water control manuals  have not been revised since projects were built decades ago and may not  reflect advances in science, such as in weather forecasting or changes in  weather patterns.
In addition, the Corps’ projects may be affected by extreme weather  events, such as flood and drought. According to the U.S. Global Change  Research Program’s May 2014 National Climate Assessment and a 2010  National Research Council’s report, precipitation patterns are changing,  and the frequency and intensity of some extreme weather events are  increasing. In addition, a 2009 USGS report found that changes in the  climate could affect water resources management and require changed  operational assumptions about resource supplies, system demands or  performance requirements, and operational constraints. For example,  according to the report, a shift in precipitation from snow to rain,  combined with earlier melting of mountain snowpack, has been  documented in western states. These two reported actions change the  timing of runoff, affecting the Corps’ operational decisions about when to  release water from reservoirs.
Section 1046 of the Water Resources Reform and Development Act of  2014 includes a provision for us to audit the Corps’ reviews of project  operations, including an assessment of whether the Corps’ practices  could result in greater efficiencies to better prepare for extreme weather.  According to a 1992 Corps’ report, project operations are defined as  water control management that is routinely required to control either water  level or flow, or both. Our report (1) examines the extent to which the  Corps has reviewed or revised selected water control manuals and (2)  describes the Corps’ efforts, if any, to improve its ability to respond to  extreme weather. Section 1046 of the Water Resources Reform and  Development Act of 2014 also required the Corps to update its 1992  report about authorized and operating purposes of its reservoirs by June  10, 2016. The updated report is, among other things, to include a plan for  reviewing the operations of individual projects that meet specified  requirements. The act also includes a provision for us to review the plan  in the updated report. However, according to officials from the Corps and  from the office of the Assistant Secretary of the Army for Civil Works, the  Corps did not update the report as required by the statutory deadline  because of funding constraints; therefore, we were unable to review the  updated report.
To address both objectives, we reviewed relevant laws and executive  orders, as well as our past reports on Corps operations and preparation  for extreme weather. We interviewed officials who are responsible for  project operations at headquarters and all eight Corps divisions. In  addition, we interviewed officials from a nonprobability sample of 15 of the  38 Corps districts responsible for water control management. We  selected these districts based on criteria such as the Corps division  where the district resides, regional differences in weather conditions, and  a range in the number of projects operating within the district. Because  this was a nonprobability sample, our findings cannot be generalized to all  Corps districts but provide illustrative examples of the Corps’ actions and  strategies. We also visited two district offices (Los Angeles and  Sacramento Districts) from our sample, where we reviewed documents,  interviewed agency officials, and observed some of the Corps’ efforts to  help prepare its operations for extreme weather. We selected these  offices based on available resources and proximity to a GAO field office,  in addition to the criteria used to select the nonprobability sample of  districts. The results from these visits are also not generalizable.
To examine the extent to which the Corps has reviewed and revised  selected water control manuals, we reviewed relevant Corps guidance  and other documents, and information on water control manual reviews or  revisions, such as engineer regulations, circulars, and manuals. We  compared agency practices with federal standards for internal control.  We focused on steps taken since 1990 because of enacted legislation  that changed the Corps’ process to revise water control manuals and  because 1990 was the last time the Corps systematically prepared  drought contingency plans for water control manuals. In addition, we  examined the Corps’ relevant documents and information on water  control manual reviews and revisions from each of the eight divisions and  our nongeneralizable sample of districts.
To examine the Corps’ efforts, if any, for improving its ability to respond to  extreme weather, we examined the Corps’ relevant guidance, documents,  and information on project operations and efforts to prepare for or  respond to extreme weather. We interviewed cognizant Corps officials to  discuss what, if any, guidance is being drafted or implemented  responding to extreme weather events at the Corps’ projects. We also  interviewed five knowledgeable stakeholders from academia, a consulting  firm, and a federal science agency to obtain their views on leading  practices in preparing operations for extreme weather. Knowledgeable  stakeholders were selected based on their knowledge of reservoir  operations, modeling precipitation patterns, and Corps operational  decisions. Views from these knowledgeable stakeholders are not  generalizable to those with whom we did not speak.
We conducted this performance audit from August 2015 to July 2016 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: This section provides information on the Corps’ organizational structure,  its project operations and water control manuals, and the process for  formulating its operations and maintenance budget.
subsections: section_title: Corps’ Organizational Structure
paragraphs: Located within the Department of Defense, the Corps has both military  and civilian responsibilities. The Corps’ civil works program is organized  into three tiers: a national headquarters in Washington, D.C.; eight  regional divisions that were established generally according to watershed  boundaries; and 38 districts nationwide (see fig. 1).
Corps headquarters primarily develops policies and provides oversight.  The Assistant Secretary of the Army for Civil Works, appointed by the  President, establishes the policy direction for the civil works program. The  Chief of Engineers, a military officer, oversees the Corps’ civil works  operations and reports on civil works matters to the Assistant Secretary of  the Army for Civil Works. The eight divisions, commanded by military  officers, coordinate civil works projects in the districts within their  respective divisions. Corps districts, also commanded by military officers,  are responsible for planning, engineering, constructing, and managing  water-resources infrastructure projects in their districts. Districts are also  responsible for coordinating with projects’ nonfederal sponsors, which  may be state, tribal, county, or local governments or agencies.
In 1969, the Corps formed the Institute for Water Resources—which is a  field-operating activity outside of the headquarters, division, and district  structure—to provide forward-looking analysis and research in developing  planning methodologies to aid the civil works program. Specifically, the  institute fulfills its mission, in part, by providing an analysis of emerging  water resources trends and issues and state-of-the-art planning and  hydrologic-engineering methods, models, and training. In 2009, the Corps  established the Responses to Climate Change program under the lead of  Institute for Water Resources to develop and implement practical,  nationally consistent, and cost-effective approaches and policies to  reduce potential vulnerabilities to the nation’s water infrastructure  resulting from climate change and variability.
section_title: Project Operations and Water Control Manuals
paragraphs: The Corps is responsible for operations at 707 dams that it owns at 557  projects across the country, as well as flood control operations at 134  dams constructed or operated by other federal, nonfederal, or private  agencies. Each of these projects may have a single authorized purpose  or serve multiple purposes such as those identified in the original project  authorization, revisions within the discretionary authority of the Chief of  Engineers, or project modifications permitted under laws enacted  subsequent to the original authorization. For example, the Blackwater  Dam in New Hampshire has the single purpose of flood control, whereas  the Libby Dam in Montana has multiple purposes, including hydropower,  flood control, and recreation.
These 841 dams and their reservoirs are operated according to water  control manuals and their associated water control plans, which Corps  regulations require to be developed. A water control manual may outline  operations for a single project or a system of projects. For example, the  Missouri River Mainstem Reservoir System Master Water Control Manual  outlines the operations at six dams and their associated reservoirs, and  the Folsom Dam Water Control Manual applies to one dam and its  reservoir. Water control manuals include a variety of information the  Corps uses in operating the dams, including protocols for coordinating  with and collecting data from federal agencies, such as NOAA’s National  Weather Service and USGS, as well as water control plans. The water  control plans, sometimes referred to as chapter 7 of the water control  manuals, outline how each reservoir is to be operated and include  relevant criteria, guidelines, and rule curves defining the seasonal and  monthly limits of storage and guide water storage and releases at a  project. According to the Corps’ engineer regulations, the Corps develops  water control plans to ensure that project operations conform to  objectives and specific provisions of authorizing legislation. Water control  plans also generally describe how a reservoir will be managed, including  how water is to be allocated between a flood control storage pool and a  conservation storage pool, which is used to meet project purposes during  normal and drought conditions. The bottom of a conservation storage  pool is considered inactive and is designed for collecting sediment (see  fig.2). Water levels in the pools are defined based on a statistical analysis  of historical rain events. For those projects that have multiple authorized  purposes, water control plans attempt to balance water storage for all  purposes.
Corps engineer regulations require that all water control manuals—except  manuals for dry reservoirs that do not fill with water unless floodwaters  must be contained—have an associated drought contingency plan to  provide guidance for water management decisions and responses to a  water shortage due to climatological drought. These plans, which can  cover more than one project: (1) outline the process for identifying and  monitoring drought at a project, (2) inform decisions taken to mitigate  drought effects, and (3) define the coordination needed with stakeholders  and local interests to help manage water resources so they are used in a  manner consistent with the needs that develop, among other things.
According to a 2014 Corps engineer regulation, water control manuals  may be revised for reasons such as land use development in the project  area and downstream from it, improvements in technology used to  operate projects, reallocation of the water supply, new regional  priorities, or changes in environmental conditions. The Corps’ engineer  regulation also directs districts to include in water control manuals a  provision allowing temporary deviations from a project’s approved water  control plan to alleviate critical situations, such as a flood or drought, or to  realize additional efficiencies without significantly affecting the project’s  authorized purposes. Districts are to perform a risk and uncertainty  analysis to determine the potential consequences of such a deviation.  Division commanders are responsible for reviewing and approving any  proposed deviations. According to the engineer regulation, deviations are  meant to be temporary and, if a deviation lasts longer than 3 years, the  water control manual must be revised.
section_title: Corps’ Operations and Maintenance Budget Formulation Process
paragraphs: Our prior work has found that the Corps’ headquarters, divisions, and  districts are all involved in developing the President’s budget request for  the Corps. The development process spans 2 years; for example,  development of the fiscal year 2018 budget began in fiscal year 2016.  After receiving budget guidance from the Office of Management and  Budget as well as the Assistant Secretary of the Army for Civil Works,  district staff compile a list of operations and maintenance (O&M) projects  necessary in their districts and submit their needs to the relevant division.  O&M projects may include, among other things, water control manual  revisions, dredging, replacement of dam parts, dam safety measures, or  adding capacity at hydropower projects. Division staff then rank the O&M  projects from all districts in the division and submit those rankings to  Corps headquarters staff for review. Headquarters staff review the  rankings to help ensure they are consistent with Corps-wide guidance  and result in decisions that emphasize agency-wide priorities.  Headquarters staff consolidate the O&M requests across business lines  and divisions into a highest-priority grouping. Once the Corps completes  its internal review of the budget request, the Assistant Secretary of the  Army for Civil Works approves and submits its budget to the Office of  Management and Budget for review. The Office of Management and  Budget recommends to the President whether to support or change the  Corps’ budget request, and the President’s budget request is transmitted  to Congress.
section_title: The Extent to Which the Corps Has Reviewed or Revised Water Control Manuals Is Unclear Because It Did Not Document Reviews or Track Revisions
paragraphs: According to agency officials, the Corps conducts ongoing, informal  reviews of selected water control manuals and has revised some of them,  but the extent of the reviews and revisions is unclear because they were  not documented or tracked. More specifically, district officials said that the  Corps reviews the manuals as part of daily operations but does not  document the reviews, and there is no guidance on what constitutes a  review or how to document it. Further, the Corps does not track  consistent information across divisions on the status of manuals to  indicate revisions that were made or are needed.
subsections: section_title: The Extent to Which the Corps Has Reviewed Its Water Control Manuals Is Unclear Because the Reviews Were Informal, According to Agency Officials, and Not Documented
paragraphs: It is unclear to what extent the Corps has reviewed its water control  manuals because district officials did not document these reviews, which,  according to district officials, are informal and conducted on an ongoing  basis through daily operations. A 2014 Corps engineer regulation states  that water control manuals should be reviewed no less than every 10  years, so that they can be revised as necessary. Most district officials  we interviewed said that they informally review the water control plan  because this portion of the manual describes how projects are to be  operated under different conditions to meet their authorized purposes.  However, officials we interviewed from all 15 districts said they do not  document these informal reviews because they consider such reviews to  be part of the daily routine of operating projects. Because these informal  reviews are not documented, knowledge of these reviews and their  results may be limited to personnel directly involved with them. Officials  we interviewed from four districts said that the loss of institutional  knowledge posed a challenge to conducting efficient reviews of manuals.  For example, officials from one district said that no Corps officials  currently employed at the district had worked on developing the manual  for a project and had no supporting documentation of the process, so the  officials did not know why prior Corps officials wrote the manual in a  particular way. As a result, the officials said it took them longer to review  the manual.
One Corps district we reviewed had previously documented informal  reviews of water control manuals. Specifically, officials we interviewed in  this district said that they documented reviews of some water control  manuals in 2005 as part of a district-wide effort to ensure these manuals  were adequate to meet the projects’ authorized purposes since they had  not been revised in a long time. According to these officials, as part of this  effort, if they determined that all of the operating conditions in a manual  were still current, they submitted a memorandum to their division that  revalidated the manual’s water control plan. Officials from that district said  they have not documented reviews of water control manuals since 2005  because they chose to focus only on those manuals they knew needed  revision. However, the Corps does not have guidance on what activities  constitute a review or how officials should document the results of their  reviews. Under federal standards for internal control, internal control and  other significant events are to be clearly documented in a manner that  allows the documentation to be readily available for examination, such as  in management directives, administrative policies, or operating manuals.  Without developing guidance on what activities constitute a review of a  water control manual and how to document that review, the Corps does  not have reasonable assurance that its districts will consistently conduct  reviews and document them to provide a means to retain organizational  knowledge and mitigate the risk of having that knowledge limited to  personnel directly involved with these reviews.
section_title: The Corps Has Revised Some Water Control Manuals but Does Not Track Consistent Information on Which Have Been Revised or Need Revision
paragraphs: The Corps has revised some water control manuals; however, divisions  and districts do not track consistent information about revisions to  manuals, and the extent to which they have been revised—or need  revision—is unclear. Corps engineer regulations state that manuals are to  be revised as needed, in accordance with the regulations. Districts have  revised some water control manuals for a variety of reasons, such as in  response to infrastructure modifications and weather events, according to  the Corps’ documents and its headquarters, division, and district officials  we interviewed. For example, officials we interviewed in one district said  they revised a water control manual after a flood highlighted a need to  change the seasonal and monthly limits of reservoir storage when water  recedes. Officials we interviewed from other districts said they revised a  manual based on vulnerabilities identified through the periodic inspections  they conduct of projects through the Corps’ dam safety program.
District officials we interviewed said that the time and resources needed  to revise manuals vary greatly, depending on the nature of the revisions  and the complexity of the project, among other things. For instance,  according to a Corps 2012 engineer regulation, all revisions to a water  control manual are to undergo a quality control review of the science and  engineering work by district leadership. Depending on the revisions  made, manuals may also undergo a technical review by division  leadership and an independent external peer review by a panel of  experts. For example, according to a Corps engineer regulation and  division and district officials we interviewed, if the districts make  substantial revisions to a manual’s water control plan, they are to  complete environmental analyses required by the National Environmental  Policy Act of 1969, which they said involves considerable time and  coordination with other federal agencies and opportunity for public  comment. District officials told us that making such substantive revisions  to a manual takes more time and resources than making an  administrative revision because of the additional requirements for  review.
Moreover, some district officials noted that the longer they defer making  revisions to a manual, the more extensive and complex the changes may  become, changes that may add time and increase costs to revise the  manual. Officials in one district said that it cost about $100,000 to revise  one section of a manual’s water control plan, which did not significantly  affect other aspects of the plan. In contrast, officials in another district  said that it cost over $10 million and took over 25 years to revise a  manual that included a water control plan for several projects, primarily  because of litigation over the revisions.
Our review of division documents indicates that all eight divisions we  reviewed tracked the date a manual was last revised, but officials told us  that the length of time since the last revision is not necessarily indicative  of whether manuals need to be revised. According to headquarters and  district officials we interviewed, water control manuals are designed to  provide flexibility for a broad variety of runoff and climatic conditions. For  example, headquarters officials said the rule curve in one water control  manual provided guidelines for how much water operators should take  out of the reservoir during October and November to meet its flood risk  management target, while at the same time holding enough water to,  among other things, meet its authorized purposes of hydropower and  providing water flow for an endangered fish species. However, two  knowledgeable stakeholders we interviewed said that many of the Corps’  rule curves assume that the chances of an extreme event are equally  likely for any given year, which may not reflect actual conditions. These  stakeholders said that the Corps should consider revising water control  manuals with dynamic rule curves to account for potential changes to  climate conditions, but a Corps official said that the science behind  dynamic rule curves is still being developed.
In addition, Corps officials said that the provisions in water control  manuals that allow temporary deviations from water control plans, if  necessary, provide districts with flexibility in operating projects. For  example, in response to drought conditions, the Corps approved a  deviation from the water control plan in December 2014 at a project in  California, a deviation that allowed the Corps to temporarily retain water  captured behind the dam following a rainstorm. According to officials in  that district, this temporary deviation allowed them to respond to the  immediate stakeholder interests in conserving water during the drought,  so they did not need to revise the water control manual. Given the  flexibilities provided by rule curves and temporary deviations, not all  manuals need to be revised, according to Corps officials we interviewed  at headquarters, divisions, and districts.
However, the extent to which water control manuals have been  substantively revised, if at all, remains unknown because the divisions  and districts we reviewed did not track consistent information about  revisions to water control manuals to help ensure that manuals are  revised in accordance with engineer regulations. For example, based on  our review of Corps documents, one of eight divisions tracked whether  the water control plans in its water control manuals reflected actual  operations of the project, but the remaining seven divisions did not. In  addition, another division tracked information about when the water  control manuals in five out of six of its districts had been revised. Officials  whom we interviewed from this division said they were not sure if any of  the manuals in the sixth district had been reviewed because information  had not been submitted by the district. Corps headquarters officials said  that the Corps does not track the status of water control manual revisions  agency-wide because two people in headquarters oversee all of the  Corps’ water resources operational issues, among other duties, and,  therefore, divisions and districts were given responsibility for tracking  revisions. However, these officials said the agency is compiling  information to create a central repository of water control manuals, among  other things, to respond to activities set forth in an action plan for the  President’s Memorandum on drought resilience. They said the  repository could be used to track the status of revisions or needed  revisions of manuals, but they do not currently plan to do so.
Furthermore, district officials we interviewed told us they have identified  certain manuals needing revision, but they have not received the O&M  funds they requested to revise these manuals and documentation shows  that they do not track consistent information on these manuals. A Corps  engineer manual states that there may be reasons—such as new  hydrologic data or a reevaluation of water control requirements—to revise  water control manuals to reflect current operating conditions. Divisions  are responsible for prioritizing the O&M funding requests they receive  from all of their districts. Corps budget documents describe factors to  consider for agency-wide prioritization—such as whether an item is  required to meet legal mandates or would help ensure project safety (e.g.,  by paving a project access road)—but headquarters officials said each  division may add other factors for consideration. According to our  document review, one of the eight divisions tracked the priority that  districts assigned to revising water control manuals when requesting  O&M funds during the budgeting process, and four divisions tracked the  fiscal year they proposed revising certain manuals, pending available  funding. However, most district officials we interviewed said revisions to  water control manuals are often a lower priority than other O&M activities,  such as equipment repairs, sediment removal, or levee repairs. As a  result, districts may not get funding to revise water control manuals.
Moreover, Corps headquarters officials said that each division and district  varies in the resources and staff it has available to conduct water control  manual reviews and make revisions. For example, officials we  interviewed from two districts in the same division said they do not have  staff available to review water control manuals, and they have not  received the funding they requested to revise their water control manuals.  Corps headquarters officials said they do not track which manuals the  districts have requested funds to revise—and therefore cannot prioritize  these requests—because they have limited staff to accomplish water  resources management activities. However, internal control standards in  the federal government call for agencies to clearly and promptly  document transactions and other significant events from authorization to  completion. Without tracking which manuals need revision, it is difficult  for the Corps to know the universe of projects that may not be operating  in a way that reflects current conditions as called for in the Corps’  engineer manual and prioritize revisions as needed.
District officials whom we interviewed said that not revising water control  manuals regularly could lead projects to operate inefficiently under  changing conditions. For example, farmers downstream from one project  wanted the Corps to consider changing operations so that their fields  would not flood when it rained. However, officials in that district said they  requested but did not receive the funds to revise the manual and could  not fully address the farmers’ concerns. Officials in another district said  they have requested funds to revise several manuals that they described  as outdated, but because they have not received funds, they noted they  were operating those projects in a way that differed from some aspects of  the approved water control plans and they did not request deviations.  Instead, they said they referred to handwritten notes and institutional  knowledge to operate those projects. For example, officials said that due  to sedimentation build up in the reservoir of one project, they are  operating that project 22 feet higher than the approved plan. According to  a Corps engineer regulation, the Corps develops water control plans to  ensure that project operations conform to objectives and specific  provisions of authorizing legislation. However, because some manuals  that need revision have not been revised and, as some district officials  noted, operations for certain projects differ from aspects of the approved  water control plans in those manuals, the Corps lacks assurance that  project operations are conforming to the objectives and specific  provisions of authorizing legislation.
section_title: The Corps Has Efforts Under Way to Improve Its Ability to Respond to Extreme Weather
paragraphs: The Corps has efforts under way to improve its ability to help respond to  extreme weather events. These efforts include developing a strategy to  revise its drought contingency plans and studying the use of forecasts to  make decisions on project operations. The Corps is also conducting  research on how to better prepare operations for extreme weather.
subsections: section_title: The Corps Is Developing a Strategy to Revise Drought Contingency Plans and Is Studying the Use of Forecasts to Make Operations Decisions at Two Projects
paragraphs: To better respond to drought, the Corps is developing a strategy to  analyze drought contingency plans in its manuals and devise methods for  those plans to account for a changing climate. According to a 2015 Corps  report on drought contingency planning, the Corps is developing the  strategy because climate change has been and is anticipated to continue  to affect the frequency and duration of drought in the United States. The  Corps last systematically prepared drought contingency plans in the  1980s through the early 1990s, before climate change information was  widely available. These plans assumed that historic patterns of  temperature, precipitation, and drought provided a reasonably accurate  model of future conditions. According to the Corps’ 2015 report, the  agency subsequently identified and reviewed all of its drought  contingency plans. The Corps’ review found (1) that none of the plans  contained information on drought projections under future climate change  and (2) that it was unlikely that the plans provided an adequate guide for  preparing for future droughts.
As of May 2016, the Corps was conducting pilot updates of drought  contingency plans at five high-priority projects to help test methods and  tools for those plans to account for a changing climate. According to the  Corps’ 2015 report, these pilot projects will help the agency develop a  framework for a systematic update of drought contingency plans. Corps  officials said these pilots are to be largely completed by the end of  calendar year 2016. The Corps has created an internal website available  to all Corps officials to disseminate the results of the drought contingency  plan analysis, pilot project results, and other drought-related information.  In addition to completing the pilot projects, Corps officials said the agency  plans to compile a list of drought contingency plan priorities by the middle  of fiscal year 2017 for inclusion in the fiscal year 2018 budget.
In addition to its efforts related to drought contingency plans, the Corps is  studying the use of forecasting tools to determine whether water control  manuals can be adjusted to improve water-supply and flood-control  operations at two projects in California—Folsom Dam and Lake  Mendocino. The Corps has historically used forecasts to some degree  in its operations, largely by using models that create a single forecast  based on the existing hydrologic data. According to Corps officials, the  Folsom Dam and Lake Mendocino projects are evaluating the potential to  incorporate forecasts into their operational rules, by using statistical  techniques to simulate multiple, slightly different initial conditions and  identify a range of potential outcomes and their probability. The use of  forecasts at these projects will depend on whether the skill of the  forecasts is improved to the point where they are viable in informing  reservoir operations. Corps officials told us that the forecasts must be  accurate in terms of space and time to allow the reservoirs to retain some  water for future supply as long as the retained water can be safely  released, if necessary, prior to the next storm.
At the first project, Folsom Dam, the Corps and the Department of the  Interior’s Bureau of Reclamation are constructing an auxiliary spillway  project to improve the safety of the dam and reduce the flood risk for the  Sacramento area. Officials also said the water control manual must be  updated to reflect the physical changes to the project, but the Corps is  also considering incorporating forecasting into its operating rules so that  prior to storm events, water can be released earlier than without  forecasting capabilities. Corps officials said the revisions to the Folsom  Dam water control manual, outlining the forecast-based operations, are  estimated to be completed in April 2017. For the second project, Lake  Mendocino, an interagency steering committee was formed to explore  methods for better balancing water supply needs and flood control by  using modern forecasting observation and prediction technology. Corps  officials told us the interagency committee expects to complete a  preliminary viability study on the project by the end of calendar year 2017.
Corps headquarters officials said that once they determine how  forecasting can be incorporated into these projects, the agency may  consider using forecast-based operations at other projects. Four of the  five knowledgeable stakeholders we interviewed said that it would be  important for the Corps to consider using such operations to help ensure  efficiency and to be able to respond to changing patterns of precipitation.  These views are consistent with our 2014 report on the Missouri River  flood and drought of 2011 to 2013, in which we recommended that the  Corps evaluate forecasting techniques that could improve its ability to  anticipate weather developments for certain projects. However, Corps  officials and knowledgeable stakeholders also said that the Corps faces  two key challenges in implementing forecast-based operations at its  reservoirs. First, four of the five knowledgeable stakeholders we  interviewed said that the Corps’ primary mission of flood control makes it  difficult for the agency to accept the uncertainty that is involved with  forecasting. Second, forecasting may be more complex in certain regions  of the country, because according to one knowledgeable stakeholder and  Corps officials, much of the rain in California is a result of atmospheric  rivers, which produce rainfall that is more predictable than the  convection rains that are experienced in the Midwest.
section_title: The Corps Is Conducting Research on How to Better Prepare Operations for Extreme Weather
paragraphs: The Corps’ Responses to Climate Change program is conducting  research on adaptation measures through vulnerability assessments for  inland projects and sedimentation surveys. In 2012, the Corps initiated  an initial vulnerability assessment that focused on how hydrologic  changes due to climate change may impact freshwater runoff in some  watersheds. This assessment identified the top 20 percent of watersheds  most vulnerable to climate change for each of the Corps’ business lines.  According to Corps officials, this assessment was conducted for  watersheds, because actionable science was not currently available to  conduct such an assessment at the project level. However, the Corps is  working with an expert consortium of federal and academic  organizations—including NOAA, the Bureau of Reclamation, USGS, the  University of Washington, and the University of Alaska—to develop future  projected climatology and hydrology at finer scales. This project is  intended to provide the Corps and its partners and stakeholders with a  consistent, 50-state strategy to further assess vulnerabilities, a strategy  that will also support planning and evaluation of different adaptation  measures to increase resilience to specific climate threats. According to  the Corps, this consortium holds monthly meetings to review progress  made by the various members. According to Corps officials, the  consortium plans to release reports in 2016 and 2017 that will enable the  Corps to improve tools, methods, and guidance for finer-resolution  analyses using climate-impacted hydrology.
The Corps has also begun to evaluate reservoir vulnerabilities to altered  sedimentation rates resulting from extreme weather and land use  changes. In 2012, the Corps began conducting 15 pilot studies at various  districts to test different methods and serve as a framework for adapting  to climate change. Two of these pilots predicted changes in the amount of  sediment in a reservoir because of changes in hydrologic variables as a  result of climate change. Additionally, according to the Corps’ website,  reservoirs in areas with drought conditions have experienced lower-than- normal levels of water in their conservation storage pools. These lower  levels have revealed additional and unexpected sedimentation in  reservoirs that could reduce the space available to store water. In 2013,  the Corps developed a program to deploy airborne laser scanning  systems to measure and collect data on the reservoirs in drought-affected  areas. In 2015, this system was tested in California to refine the process  to collect sedimentation data and modify the system for specific aircraft.  According to a Corps official we interviewed in the Responses to Climate  Change program, the agency plans to further refine the data collected  and evaluate how these data change over time. This effort, the official told  us, is also expected to provide indicators to support the analysis of future  sedimentation rates based on climate changes for use in the Corps’  climate vulnerability analysis. The official said a baseline report on the  Corps’ reservoir sedimentation status is expected by the end of fiscal year  2016. This effort was highlighted in the action plan for the President’s  Memorandum on Building National Capabilities for Long-Term Drought  Resilience, which lays out a series of activities to fulfill the President’s  drought-resilience goals.
section_title: Conclusions
paragraphs: The Corps has revised some of the water control manuals used to  operate its water resources projects, which serve important public  purposes such as flood control, irrigation, and water supply. But district  officials told us there are manuals that do not reflect the changing  conditions in the areas surrounding the projects. A Corps engineer  regulation states that the water control manuals should be reviewed no  less than every 10 years and revised as needed. However, there is no  Corps guidance on what activities constitute a review, and while district  officials said they informally reviewed selected water control manuals  through daily operations, they also said they do not document these  reviews. Without developing guidance on what activities constitute a  review of a water control manual and how to document that review, the  Corps does not have reasonable assurance that its districts will  consistently conduct reviews and document them to provide a means to  retain organizational knowledge and mitigate the risk of having that  knowledge limited to personnel directly involved with these reviews.
In addition, while the Corps has revised certain water control manuals in  accordance with its engineer regulation, it does not track consistent  information on revisions to its manuals. Furthermore, district officials said  that they have requested funds to revise additional water control manuals  as needed to reflect changing conditions, but they have not received  those funds, and have not tracked consistent information about manuals  needing revisions. However, internal control standards in the federal  government call for agencies to clearly and promptly document  transactions and other significant events from authorization to completion.  Without tracking which manuals need revision, it is difficult for the Corps  to know the universe of projects that may not be operating in a way that  reflects current conditions as called for in the Corps’ engineer manual and  to prioritize revisions as needed. Because some manuals that need  revision have not been revised and some district officials noted that  operations for certain projects differ from aspects of the approved water  control plans in those manuals, the Corps lacks assurance that project  operations are conforming to the objectives of authorizing legislation.
section_title: Recommendations for Executive Action
paragraphs: To help improve the efficiency of Corps operations at reservoir projects  and to assist the Corps in meeting the requirement of the Water  Resources Reform and Development Act of 2014 to update the Corps’  1992 reservoir report, we recommend that the Secretary of Defense direct  the Secretary of the Army to direct the Chief of Engineers and  Commanding General of the U.S. Army Corps of Engineers to take the  following two actions: develop guidance on what activities constitute a review of a water  control manual and how to document that review; and  track consistent information on the status of water control manuals,  including whether they need revisions, and prioritize revisions as  needed.
section_title: Agency Comments
paragraphs: We provided a draft of this report for review and comment to the  Department of Defense. In its written comments, reprinted in appendix I,  the department concurred with our recommendations and noted that it will  take steps to address these recommendations as it updates its guidance.  In its comments, the department also stated that, as of May 2016, it had  updated its Engineer Regulation 1110-2-240, Engineering and Design:  Water Control Management. We incorporated this information into the  report.
We are sending copies of this report to the appropriate congressional  committees, the Secretary of Defense, and other interested parties. In  addition, the report is available at no charge on the GAO website at  http://www.gao.gov.
If you or your staff members have any questions about this report, please  contact me at (202) 512-3841 or fennella@gao.gov. Contact points for  our Offices of Congressional Relations and Public Affairs may be found  on the last page of this report. GAO staff who made key contributions to  this report are listed in appendix II.
section_title: Appendix I: Comments from the Department of Defense
section_title: Appendix II: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, key contributors to this report  included Vondalee R. Hunt (Assistant Director), Cindy Gilbert, Richard  Johnson, Cynthia Norris, Dan Royer, Holly Sasso, Jeanette Soares, and  Michelle R. Wong.