Detailed Information on the
Bureau of Reclamation - Safety of Dams Program Assessment

Evaluate the recommendations of the National Research Council's recent report as they relate to the Safety of Dams program, especiallly as those recommendations relate to the Technical Service Center.

Fully implement Reclamation's Safety of Dams Act, as amended, to further enhance Project Beneficiary involvement by: 1) providing project beneficiaries written notice; and 2) considering cost containment measures recommended by beneficiaries.

Integrate more detailed program performance information into Reclamation's budget request for the dam safety program.

Track and accomplish performance targets.

Measure: Complete Comprehensive Facility Reviews (CFR's) of every high and significant hazard dam once every six years.

Explanation:Reclamation inspects and reviews (CFR) each high and significant hazard dam once every six years. On average, 42 CFR examinations and reports should be completed annually to meet Reclamation's CFR goal. Reclamation uses CFR's to identify and address Dam Safety issues in a timely manner. Ensuring CFR's are completed is an effective indicator for reducing risk to the public.

Measure: Percent of dam safety component score within the Facility Reliability Rating (FRR).

Explanation:The FRR is a numerical rating from 0 to 100 which reflects the overall reliability of the facility; 35 of these points are related to dam safety. For each high and significant hazard dam, the possible score of 35 is reduced based on dam safety operational restrictions and risks that exceed Reclamation guidelines for public protection. The score will also be affected if dam safety recommendations and decisions are not addressed, including a structural modification, in a timely manner. The overall score (maximum of 345) is divded by 35 to determine the percentage of the dam safety-related FRR score. The objective is to maximize the percentage achieved each year which indicate reduced risk to the public and to impacts on water management. Tracking this measure will also identify program effectiveness in identifying and resolving dam safety issues.All of Reclamation's high and significant hazard dams were first benchmarked in 2003.

Measure: Estimated annualized loss of life risk per dam.

Explanation:This represents the total risk posed by all high and significant hazard dams divided by the number of dams with risk data. This measure is an indicator of the Initiate Safety of Dams Corrective Aciton (ISCA) program effectiveness in reducing risk to the public. The numerator is the total risk as presented in Safety of Dams total risk portfolio. The denominator is the total number of dams in Reclamation's inventory with calculated risk data. Risk data is currently available for 230 dams. It is anticipated risk data for the remaining 15 dams (total 245) will have risk data calculated as part of a CFR in the next year. It is not anticipated this measure will be effected significantly by the addition of this data.

Measure: Percent of Decision Documents related to dam safety isues at high and significant hazard dams, completed within 60 days of source document completion.

Explanation:All decisions with regard to Safety of Dams recommendations and issues are formally documented in decision documents. Reclamation guidance requires that all decision documents be completed within 60 days of the completion of the source document (CFR, PFR, AFR issue evaluation), i.e., the document which identifies the basis for a dam safety concern. In order to reduce risk to the public it is critical that decisions related to dam safety issues are completed in a timely manner. Tracking this measure will provide insight into the effectiveness of the program with regards to timely decision making to reduce risk.

Measure: Percent of Safety of Dams recommendations that have been completed.

Explanation:Safety of Dams recommendations result from facility reviews or observed performance abnormalities. Dam Safety recommendations are made to further evaluate or to correct dam safety deficiencies. This measure indicates the long term effectiveness of the SEED program in addressing dam safety deficiencies. The number of dam safety deficiencies is an indicator of dam safety risk. Tracking this measure also indicates the long-term reduction of risks to the public, public safety, property and/or the environment. Tracking this measure will also help to better manage the program by indicating if Program resources adequately directed to identify and address Safety of Dams recommendations. The numerator is the number of recommendations completed as of that particular year. The denominator is the total number of recommendations made up to that particular year, including recommendations that carried over from prior years.

Is the program purpose clear?

Explanation: The purpose of the program is to ensure that Reclamation water storage facilities do not present unreasonable safety risks to the public, public safety, property, and/or the environment. The program accomplishes this through monitoring and periodically evaluating the physical status of its facilities, and based on the results of those revews, assessing the risk of any threat to loss of life, property damage, or loss of project benefits. It then considers options to ameliorate that risk, weighs the costs and benefits, and acts accordingly.

Evidence: Federal Guidelines for Dam Safety, Departmental Manual 753 DM 1 and 2, Reclamation's Safety of Dams Act, Reclamation's Mission Statement, Guidelines for Achieving Public Protection in Dam Safety Decision Making, Dam Safety Program Mission Statement.

Does the program address a specific and existing problem, interest, or need?

Explanation: The Dam Safety Program addresses the specific problem of the safety of Reclamation's dams, by monitoring and evaluating those facilities thought to pose a potential threat, and taking corrective actions as necessary to mitigate that risk. Congress authorized the Dam Safety Program through the Reclamation Safety of Dams Act of 1978 to address safety issues associated with future potential dam failures. As these dams age, the need for close scrutiny increases. Water control structures such as dams and levees are integral parts of water development projects that have significant economic benefits, and in many instances are integral to local, regional, and national infrastructure. However, the potential sudden and catastrophic release of their waters can result in significant damage, to the extent that the Department of Homeland Security has classified them as Weapons of Mass Destruction. Such releases would also result in the loss of project benefits. Additionally, the high-profile nature of dams and the spectacle and violence of dam failure means that the number of lives lost from a catastrophic dam release disproportionately impacts the public psyche.

Evidence: Reclamation manages 476 dams and dikes. The Dam Safety Program includes 245 high and significant hazard dams. A high or significant hazard dam is a facility in which failure or misoperation could cause loss of human life and/or significant property or environmental damage. Over one half of these are more than 50 years old, and about 90 percent were built prior to the adoption of current state-of-the-art design and construction practices. Examples of failures and near-failures of dams or of dam components include the Teton Dam Failure (6/6/76), Fontenelle Dam (narrowly averted failure) (1964) (1982), Willow Creek Dam (discovered sinkhole in dam) (1996), Kecheelus Dam (actions to monitor risk concerns caught it in the process of failing) (1998); ASCE Infrastructure Report Card, Data on construction dates for Reclamation Dams.

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: The Dam Safety Program applies to those dams specified by the Reclamation Safety of Dams Act of 1978 as amended. No other Federal, state, local or private sector has jurisdiction or responsibility. In addition, only those Reclamation water storage facilities, where failure or misoperation could cause loss of human life and/or significant property or environmental damage (high and significant hazard) are included in the Dam Safety Program. All other Reclamation water storage facilities are evaluated and maintained outside the Dam Safety Program. The National Dam Inspection Act specifically excludes dams under the jurisdiction of Reclamation. However, Reclamation does some dam safety work on other Department of the Interior Dams, such as the Bureau of Indian Affairs.

Evidence: Reclamation Safety of Dams Act of 1978, as amended, Departmental Manual 753 DM 1 and 2, Reclamation Manual FAC 06-01 Reclamation Dam Safety Program, Reclamation Manual FAC 01-07 Review/Examination Program for High and Significant Hazard Dams, National Dam Inspection Act.

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: The program, built around the authority given it by the Reclamation Safety of Dams Act, is well-designed to meet the technical needs of monitoring and evaluating its dams, and formulating and implementing actions to mitigate any adverse findings, ultimately meeting its objectives of ensuring water storage facilities do not pose unreasonable risks. Annual program reviews by boards of independent consulting engineers have exposed no serious flaws in the program. Recommendations for improvement have been addressed in a timely manner. The program has several practices that while they do not impede its effectiveness or efficiency may have unintended budget and policy consequences - none of them would appear to jeopardize public safety. For example: -- Risk anslysis methodologies create a situation where a dam that does not have an increased risk of failure could have an increased potential loss-of-life, due to a growing downstream population-at-risk. This in turn could result in corrective actions for a dam that is not any less safe than it was before, except in terms of a growing downstream population at risk. -- Advances in the engineering state-of-the-art make it possible that a dam could be targeted for SOD corrective actions based on retrospective deficiencies in design. --The generous 85% Federal cost-share far exceeds what project sponsors would pay for the original project construction (which is 100% reimbursable). -- Present economic analysis practices of the program justify a safety of dam corrective acion by calculating the net present value of project benefits. However, project benefits were already used to justify the original dam construction, based on a benefit-cost analysis with a project life of 50 years, with reimbursable costs generally at 100% (depending on the specifically-authorized project purposes). This raises the question of why the original project, in those cases where it has exceeded its original 50-year planning horizon, should be 100% reimbursable, and the additional benefits secured from doing dam safety work should be an 85% Federal cost. -- Additionally, high-value homes in the Population-At-Risk (PAR) area can result in inflated project benefits or increased project economic losses from dam failure, so that wealthy neighborhoods are more likely to be the beneficiaries of dam safety actions than those that are not wealthy (this problem is not uncommon for economic evaluations of many kinds of water development projects). -- The broad scope of the program's authorization can lead to outcomes where a reasonable person would say that the dam had been entirely replaced, instead of components merely being upgraded or rehabilitated.

Evidence: Reclamation Safety of Dams Act of 1978, and amendments, Independent Review Panel Reports; various project reports for Safety of Dams programs proposed modifications.

Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?

Explanation: Risk assessment is the basis of targeting resources to reduce risk to the three groups of beneficaries: the project sponsors (such as irrigators and power users) of a particular dam, the PAR from a dam failure, and the broader public in terms of the psychological impact of a dam failure, broader disruption of infrastructure, etc. Risk assessment provides the fundamental basis for decision making, prioritization and verification to ensure resources are being targeted to the highest risk reduction activities. Technical analysis and recommendations resulting from inspections and the evaluation of specific issues are peer reviewed both internally and in many cases by external consultants. Decisions regarding Reclamation's actions to address risk are made through collaboration of the Regional Director, the Area Manager and the Chief, Dam Safety Office and are documented. Risk assessment also provides the basis for separating Operations and Maintenance (O&M) activities from dam safety activities. O&M activities at facilities address routine maintenance issues and occur without the Dam Safety Program and are not subsidized by the Dam Safety Program.

Evidence: Reclamation Manual FAC P02 Decisions related to Dam Safety Issues, Guidelines for Achieving Public Protection in Dam Safety, Section 4(a) of the Reclamation Safety of Dams Act.

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: The program has two long term performance measures that focus on outcomes. The first measure, Percent of Safety of Dams recommendations that have been completed, indicates the reduction in dam safety risk, over time, to the public, public safety, property and/or the environment, based on a baseline of backlogged recommendations. The second measure, Total Annualized Loss of Life/dam, is a measure of the reduction in risk of loss of life, over time on a per dam basis. Safety of Dams recommendations are the result of facility reviews or observed performance abnormalities. Dam Safety recommendations are made to further evaluate or to correct dam safety deficiencies. Reducing deficiencies will therefore reduce the risk to the public. Tracking this measure will also help to better manage the program by demonstrating if resources are adequately directed to identify and address Safety of Dams recommendations.

Evidence: Data on historic SOD recommendations. Facility risk prioritization is a total measure of the risks (quantified through risk assessment) presented by Reclamation facilities to the public. The risks are the product of the probability of failure and the consequences of a failure for individual facilities. The facility risk prioritization is a summation of the risk for all the facilities divided by the total number of facilities that have had risk assessments performed.

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: The program targets are ambitious in that they aggressively seek to reduce risk to the public. Targets are designed to promote continuous reduction in risk and to demonstrate the long term effectiveness of the program. There is significant and clear baseline data to demonstrate the overall trend in reducing the number of Safety of Dams recommendations and the annualized loss of life.

Evidence: DSIS data on historic SOD recommendations has been collected since the year 2000. Since 2000 the program has aggressively reduced the number from 880 to 500 in 2004. Continuing to increase the percentage of complete recommendations will become more difficult with time, especially as the backlog is addressed, and given that facilities continue to age, the engineering knowledge base continues to grow and populations downstream of dams continue to grow, all of which tend to increase the number of recommendations, with two of these factors indicating an actual increase in risk. Dam Safety Office (DSO) facility risk prioritization or annualized loss of life per dam is a new measure with significant baseline data.

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: The dam safety-related portion of the Facility Reliability Rating (FRR) is a discreet and quantifiable annual performance outcome. The FRR is a numerical rating from 0 to 100 which reflects the overall reliability of the facility; 35 points of this are related to dam safety, through the Reservoir Operating Restrictions and Dam Safety Program components of the FRR. The score will be affected if there is a reservoir and operating restriction for dam safety reasons. The score will also be affected if dam safety recommendations and decisions, including a structural modification, are not addressed in a timely manner. Tracking this identifies program effectiveness in identifying and resolving dam safety issues, and the resultant reduction in risk to the public. The FRR ties into other maintenance issues at Reclamation. The FRR is also included as a measure for a GPRA goal (UIM 5.1.01): Operate and Maintain a Safe and Reliable Water Infrastructure.

Evidence: The FRR, a compilation of results from individual facilities. Bureau of Reclamation FY 2004 Operating Plan, Bureau of Reclamation FY 2005 Operating Plan (Draft).

Does the program have baselines and ambitious targets for its annual measures?

Explanation: Reclamatin has developed a baseline and ambitious targets for the annual measure. The FRR for all of Reclamation's high and significant hazard dams were first benchmarked (baseline data) in 2003. The FRR is included in a GPRA goal for the FY 2004 and FY 2005 Bureau of Reclamation Operating Plans with a specific annual target. The Dam Safety Program has established ambitious annual targets for specific components, as described above, of the FRR.

Evidence: The FRR, a compilation of results from individual facilities. The goal of 90% of the 35 dam safety related FRR score in 2005 is ambitious given the accomplishments of 88% in 2004. Bureau of Reclamation FY 2004 Operating Plan, Bureau of Reclamation FY 2005 Operating Plan (Draft).

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: The project beneficiaries support the overall goals of the program by performing and participating in the dam safety process. However, the beneficiaries' goal of delivering water at the least possible cost is not always consistent with the cost of actions necessary to ensure dam safety. The Dam Safety Program is carried out through the Dam Safety Office, Reclamation Technical Service Center (TSC), the Regional and Area offices. Partners include project beneficiaries and water districts. The perspective of the project benificiaries is represented by the Area Manager and Regional Director in the decision making process. The Reclamation Safety of Dams Act, 1984 Amendment requires that 15% of the total costs for Safety of Dams modifications be reimbursable by the project beneficiaries. The Program provides project beneficiaries the opportunity to participate in the SOD Modification process, including opportunities to submit alternative design concepts for formal consideration. The Regional and Area offices and project beneficiaries perform and participate in dam-safety related facility evaluations; decisions on potential actions are made by a decision making triad composed of the Chief, Dam Safety Office, Regional Director and Area Office Manager. The Regional and Area Office Mangers report annual performance as it relates to accomplishments of Program goals.

Evidence: Reclamation Manual FAC P02 Decisions related to Dam Safety Issues, Reclamation Manual FAC 01-06 Annual Reporting for Dam Safety, Security & Related Operations, Reclamation Manual FAC 01-07 Review/Examination Program for High and Significant Hazard Dams, Annual Dam Safety Assessment Report, Program Accomplishments Fiscal Year 2004, Reclamation Safety of Dams Act of 1978 and Amendments.

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: The Dam Safety Program has an established process for annual, independent program evaluations, and has a record of addressing pertinent recommendations. These evaluations meet the criteria of independence, frequency, and quality. They meet the criteria for scope sufficient to receive a "Yes" for this question, but did not evaluate broader issues of long-term impacts and challenges for the dam safety program. The Dam Safety Program undergoes an annual evaluation as required in Reclamation Manual FAC-01-06. This evaluation is conducted by an internal Dam Safety Officer and an Independent Review Panel (IRP) comprising independent consulting engineers with significant world-renowned dam safety experience. The scope includes an assessment of the overall effectiveness of the basic components of the Dam Safety program and the technical and administrative practices that support these components. These program evaluations have been conducted annually since 1997. Recommendations for improvement have been addressed in a timely manner.

Evidence: Annual Dam Safety Assessment Report, Program Evaluation Portion, Draft - March 24, 2005.

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: There is not a clear linkage between budget requests and the ability of the program to achieve the targets for its performance measures, or even of what resources are necessary from a qualitative perspective. This is particularly true because performance measures developed during the PART process did not exist for prior budget requests. Even though the level of detail is is not sufficiently transparent to receive a'yes' answer, funding, policy or legislative decisions have a clear impact on the program's ability to identify, evaluate (Safety Evaluation of Existing Dams- SEED) and correct (Initiation of SOD Corrective Actions - ISCA) dam safety deficiencies and therefore reduce risk to the public. However, the FY06 request did include a greater level of detail regarding actions to be undertaken at particular facilities. While this is not enough to meet the criteria necessary for a "Yes", the recent direction of budget and performance integration has been positive, and hopefully will continue to improve.

Evidence: FY 2005 SOD program budget, ISCA Plan for Future Award of Corrective Actions, Current Dam Safety Accounting Report. SEED and ISCA are separate line items in the annual program budget. The SEED budget reflects the consistent need to periodically identify and evaluate facilities. The ISCA budget request reflect the cyclical nature of funding needs relative to the prioritization of actions with regard to risk. All direct and indirect costs are reported and included in the total cost to administer the program. In addition, monthly Dam Safety Accounting Reports are developed and distributed to stakeholders for disemination.

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: The Dam Safety Program is dilligent about taking and documenting its responses to address any strategic planning deficiencies identified through independent reviews (IRP's). The annual IRP process provides the program with valuable input from independent consulting engineers who help to continuously fine-tune the strategic focus. The program documents these actions in the Annual Dam Safety Assessment Report, Program Accomplishments. In 1998, the program has shifted from decision making on the basis of engineering judgement and engineering standards to incorporate risk analysis as the primary indicator of the need for risk reduction actions.

Evidence: Annual Dam Safety Assessment Report, Program Accomplishments, Guidelines for Achieving Public Protection in Dam Safety Decisionmaking.

Has the agency/program conducted a recent, meaningful, credible analysis of alternatives that includes trade-offs between cost, schedule, risk, and performance goals, and used the results to guide the resulting activity?

Explanation: The program conducts systematic, meaningful, and credible analysis of alternatives during the Safety of Dams modification process including: 1) Corrective Action Studies, which consider different conceptual design alternatives; 2) An Independent Consulting Review Board (CRB) comprising experts, to refview all critical aspects of a project; 3) Value Engineering Studies (VE) are performed on all projects with construction costs in excess of $1 million;4) National Environmental Policy Act (NEPA) and Cultural Resource permitting processes are applied to all projects.

Evidence: Safety of Dams Project Management Guildelines, March 2003, Chapter III - Preconstruction Activities, defines the processes and requirements for alternative analysis.

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: The Dam Safety Program Office regularly collects data on the status of decision documents, facility reviews, SOD Modification, SOD related O&M issues and FRR. Reclamation's Technical Service Center (TSC) is a partner that provides services to the program office. All TSC services are provided on a reimbursable basis through the use of service agreements. Service agreements are negotiated on a task basis and not less than annually for those agreements which span more than one fiscal year. Monthly status reports, including performance data, are required on all service agreements in excess of $50,000. The program office uses this information to allocate resources, adjust program priorities and take other appropriate management action. The program has been collecting data for several years and has baseline data to set performance targets.

Evidence: Sample Area Office Annual Report, Annual Dam Safety Assessment Report, Program Accomplishments, sample Monthly Status Report, sample Performance Feedback Form, sample Dam Safety Project Schedule, CFR Schedule, Monthly SEED and ISCA expenditure reports.

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: Dam Safety Decisionmaking authority resides with the Chief, Dam Safety Office, the Regional Director and the Area Office Manager. The Delegation of Decisionmaking Authority Guidelines further delegate decisionmaking authority to Program Managers as appropriate. In addition the TSC identifies team leads for all service agreements. The Performance Plans for the Program Managers and partners include elements related to the FRR. The Performance Plans for team leaders from the TSC include elements related to supporting the mission of the Dam Safety Program and the goal of reducing risk to the public. In addition, the program office provides performance feedback to the TSC, regional and area offices on program accomplishments.

Evidence: Bureau of Reclamation, Dam Safety Office, Delegation of Decisionmaking Authority Guidelines, August 2002, Sample Performance Plan element related to FRR, sample team leader Performance Plan element, Performance Feedback Form.

Are funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?

Explanation: Program funds are obligated consistent with the overall program plan and less than $100K of unobligated funds remain at the end of the year. The program and program partners establish schedules, annually, for program obligations which correspond to the program needs. Spending reports are produced monthly and compared to the obligation schedules and the intended use of the appropriated fund. However, programmatic annual goals are broad enough that there is a wide degree of flexibility in moving funds within the dam safety program, without triggering reprogramming guidelines. If one project is falling behind schedule, it is relatively easy to divert funds to another that may have additional capability. The program is defined broadly enough that 'intended purpose' can include a wide variety of actions other than what was specifically intended by the original request for Federal funding.

Evidence: Spending reports are produced monthly and at the end of each fiscal year, include sample spending report, Dam Safety Program Annual Budget Meeting Notes, History of Funding for Safety of Dams Program.

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: The program has procedures in place to promote and measure efficiency and effectiveness, including an efficiency measure with a well-established baseline and recently-established targets for its efficiency measure. The program has procedures in place through the peer review, Dam Safety Advisory Team, decision making triad, Corrective Action Studies-Corrective Action Alternatives process, and project beneficiary involvement to ensure the risk reduction actions are accomplished with the least total project costs. The Dam Safety program has implemented a Project Management Team (PMT) approach for dam safety corrective actions. The PMT's role is to manage the project for the client (decision making triad) to ensure effective program accomplishment and execution of an efficient and cost-effective project process. Value Engineering (VE) studies are performed on all projects and construction costs in excess of $1M. VE studies are performed to review if the project scope has considered cost saving alternatives. Once the project scope has been determined, state-of-the-art project management principles, including earned value analysis, are utilized to ensure projects are managed efficiently.

Evidence: Safety of Dams Project Management Guidelines, Reclamation Manual - Total Design Process, TSC Project Management Guidelines.

Does the program collaborate and coordinate effectively with related programs?

Explanation: The program has a long history of working closely with other federal, state, local, and private entities, as well as professional societies, involved with dam safety issues.

Evidence: The National Dam Safety Act, ICODS Risk Analysis Subcommitteee Charter, ICODS Training subcommittee Charter, ICODS Federal Guidelines for Seismic Ground Motions, DOI Dam Safety Coordinators Conference Agenda, USACE Partnership Agreement. The program collaborates with and participates on: The National Dam Safety Review Board on the reauthorization of the National Dam Safety Act, research efforts to improve dam safety at Federal and state levels. Inter-Agency Committee on Dam Safety (ICODS) - Efforts to coordinate training of qualified dam safety engineers, efforts to further the acceptance and use of risk based decisionmaking nationwide. DOI - Annual conference to share dam safety experience across DOI Dam Safety Programs and to provide training for bureau staff in specific and non-technical areas relevant to dam safety. U.S. Army Corp of Engineers (USACE) - partnership agreement includes provisions for addressing MOU's for dam safety. Folsom Dam- coordination of Reclamation operations, dam safety and USACE flood control projects with USBR, USACE, SAFCA, State.

Does the program use strong financial management practices?

Explanation: Financial management systems meet statutory requirements. Financial information is accurate and timely. There are integrated financial and performance systems in place to support day-to-day operations. The program is free of material internal control weaknesses reported by auditors. However, in recent years there has been at least one incident of costs being inappropriately attributed to the Safety of Dams program (with its 15% local cost-share), when they should have been considered Operations and Maintenance expenses (100% local responsibility), resulting in a signficant unintended subsidy of local project sponsors.

Evidence: Spending reports are produced monthly and at the end of each fiscal year, Dam Safety Program Annual Budget Meeting Notes, History of Funding for Safety of Dams Program. Addendum to Safety of Dams Modification, Bradbury Dam, Cachuma Project, California. Letter from OMB to Bureau of Reclamation regarding Addendum of Safety of Dams Modificatin, Bradbury Dam, Cachuma Project, California.

Has the program taken meaningful steps to address its management deficiencies?

Explanation: The program utilizes a system of annual independent review panels (IRP's) for identifying program management deficiencies and uses the system to make necessary corrections in a timely manner. The program is taking steps to refine the role of the PMT to further ensure program funds are expended appropriately to ensure program accomplishment.

Evidence: Annual Dam Safety Assessment Report, Program Evaluation Portion, Draft - March 24, 2005, Annual Dam Safety Assessment Report, Program Accomplishments, Fiscal Year 2004.

Is the program managed by maintaining clearly defined deliverables, capability/performance characteristics, and appropriate, credible cost and schedule goals?

Explanation: The program is managed to focus on its main deliverable of reducing risk at its dams. The deliverables are dam safety decisions, reports and construction. Decisions are tracked and reported in the program's efficiency measure. Also, Reclamation has in place various contracting and construction quality control methods to ensure that specificed project completion parameters are achieved. Documentation of successful completion of risk reduction actions is signed by the Chief, Dam Safety Office, the Regional Director and the Area Office Manager. In addition, the program conducts periodic Comprehensive Facility Reviews on Reclamation facilities after substantial completion to re-evaluate risks and the success of risk reduction actions.

Evidence: Safety of Dams Project Management Guidelines, March 2003, Chapter III - Preconstruction Activities, Chapter IV - Construction Activities, Chapter V Postconstruction Activities. Identifies and defines the required quality, capability, and performance characteristics and objectives expected of the end products.

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: The program is on track to meet the long term goal of reducing the number of incomplete SOD recommendations within the timeframes. In 2000 the number was 880 and by the end of FY 2004 the number had been reduced to 500. At the end of FY 2005 the performance target is 450. The program partners - TSC, Regional and Area Office and project beneficiaries - are committed to the program long term goals as witnessed by their stake and involvement in the process. In terms of reducing risk to the public, as of September 30, 2004, the Bureau of Reclamation has taken corrective actions to reduce risk at 84 high and significant hazard dams. Sixty-nine of these risk reduction corrective actions are complete, two of them are in on-going construction status, four are in various stages of OMB review or Commissioner approval, and nine of these Safety of Dams projects are in varying stages of MOD Report preparation.

Evidence: Historical performances data showing the reduction in the number of SOD Recommendations, Historical data showing the completion of CFR's every 6 years for each dam, Bureau of Reclamation FY 2005 Operating Plan demonstrating GPRA goal achievement.

Does the program (including program partners) achieve its annual performance goals?

Explanation: The annual performance measures are too new to assess whether targets are met, although some progress is certainly being made. While it appears that some targets have been met, some of those targets have been populated retroactively. Retroactive population of targets is not sufficient to achieve a 'yes'.

Evidence: Historical performance data showing dam safety related FRR scores, Fiscal Year Final Quarterly Decision Document Status Report, Bureau of Reclamation FY 2005 Operating Plan demonstrating GPRA goal acheievement.

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: The program deserves a rating of "Yes" because its efficiency measure shows improvement, and because of the program's recent A-76 competition. The program completed an A-76 competition in FY 2004, which helps demonstrate efficiency. Similarly, the contract-based nature of the construction work ensures a certain level of competitiveness. The efficiency measure should be able to demonstrate improvement over time. However, at present, the measure was populated retroactively, and the actuals do not represent management toward achieving a particular target.

Evidence: Fiscal Year Final Quarterly Decision Document Status Report.

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: A benchmark exercise was completed in 2002 with 15 dam owners including Reclamation, TVA, BPA, and USACE. The study conclusion was that it was difficult to directly compare dam safety programs with significantly varying scopes, authorities and budget structures. However, the program's progressive use of risk-based assessments demonstrates that it is a leader in the field. Also, its long-standing use of outside teams of reviewers, its close collaboration with other dam safety professionals, and its diligent follow-up on responding to (and often implementing) the recommendations of outside reviewers altogether argue for a favorable comparison with other programs, even though the one formal evaluation done on the topic was inconclusive.

Evidence: Tennessee Valley Authority, Dam Safety Benchmarking Study (Proprietary Information, not duplicable)

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: The Dam Safety Program undergoes an annual evaluation as required in Reclamation Manual FAC 01-06. This evaluation is conducted by an Independent Review Panel (IRP) composed of independent consulting engineers with significant dam safety experience. The scope is broad and includes an assessment of the overall effectiveness of the basic components of the Dam Safety Program and the technical and administrative practices that support these components. The conclusion of this independent evaluation, completed in March 2005, was that: "Reclamation's Dam Safety Program is comprehensive, well organized, and is being carried out diligently by Reclamation staff throughout the organization". In addition, within the Effectiveness of Actions to Reduce Risk section the IRP goes on to say, "Reclamation is effective in taking action to reduce risk particularly where the risk is apparent and easily communicated to all those who must participate in the risk-reduction effort".

Evidence: Annual Dam Safety Assessment Report, Program Evaluation Portion, Draft - March 24, 2005.

Were program goals achieved within budgeted costs and established schedules?

Explanation: Program goals are, to a certain extent, achieved within budgeted costs and established schedules. Some recent safety of dams modification projects have exceeded budgeted costs, requiring addendums to the modifications reports to Congress for Bradbury, Kecheelus, and Clear Lake Dams. The data suggest that the program has a mostly effective track record of budget and schedule control. 72% of SOD projects have been completed within the budgeted authority; however, another way of looking at this is that 28%, or nearly a one-third, of dam safety projects have exceeded their budgeted costs, which is troubling. A recent study by the National Research Council suggests that Reclamation has some problems with its cost estimates, and the recent performance of the Dam Safety program seems to support that finding.

Evidence: Safety of Dams Modification spreadsheet. " Managing Construction and Infrastructure in the 21st Century Bureau of Reclamation", National Research Council, Prepublication copy, 2005.