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Scope and Organization of the Glen Canyon Environmental Studies INTRODUCTION The scope of the Glen Canyon Environmental Studies (GCES) of the Bureau of Reclamation program changed considerably between its inception in 1983 and its termination in 1995. In fact, one weakness of GCES was the instability of its conceptual and geographic boundaries. The scope and organization of GCES are instructive in part because they reflect beneficial maturation of the Bureau of Reclamation's (BOR) environmental analysis effort and in part because they illustrate some difficulties inherent in gov- ernment environmental research projects. SCOPE AS DEFINED BY MANAGENIENT OPTIONS, RESOURCES, AND THE ECOSYSTEM CONCEPT Management Options il The objective of GCES was to establish a basis for forecasting the ways n which various options for managing Glen Canyon Dam would affect all resources of value to society. In light of this objective, it is remarkable that GCES management failed to develop and feature a comprehensive list of management options in planning GCES. Part of the explanation lies in the resistance of the BOR itself to the consideration of management options that were beyond its planning horizon. For example, the BOR, with encour- agement from the U.S. Department of Energy's Western Area Power Admin 24

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Scope and Organization of the GCES 25 istration (\/VAPA), initially resisted any notion that the dam could be managed in a way that would be inconsistent with the production of maximum power revenues as reflected by historical operation of Glen Canyon Dam (BOR, 1995~. Thus, GCES at first was restricted to studies that reflected far less than a full slate of options. In fact, the resistance to consideration of all options extended well beyond BOR to virtually every other agency and constituency. Agencies, groups, and individuals, including scientists, have commonly judged management options on a mainly intuitive or single-factor basis. As pointed out in the first National Research Council (NRC) review of GCES (NRC, 1987), GCES under the direction of the BOR should have been planned around a list of all management options not precluded by law or unrealistic in cost or feasibility. Table 2.1 provides such a list. As shown by the table there is considerable flexibil ty for management of resources through variations in the operation of Glen Canyon Dam within the legal requirements for delivery of water and prudent protection of the dam from catastrophic flooding. Had such a list originally been part of GCES planning, the studies would have been directed more quickly toward the questions that management ultimately faces. Instead, the items on the list were acknow- ledged incrementally over about a decade. During preparation of the operations environmental impact statement (EIS) in 1994, and with encouragement from the 1992 Grand Canyon Protection Act, the BOR embraced the principle of adaptive management. In following this laudable principle, the BOR committed itself to frequent review of management options (Table 2.1), along with a list of resources, and to adjust management practices as necessary to optimize the aggregate value of all resources. GCES would have proceeded more efficiently had the BOR recognized this need initially rather than toward the end of the program, but the final adoption of adaptive management through the EIS is an important achievement for GCES and for the BOR. Resources Resources potentially affected by variations in the operation of Glen Canyon Dam are listed in Table 2.2. Until the BOR began responding to the results of GCES (ca. 1985), the dam had been managed entirely around water storage and delivery, flood prevention, and the production of power revenue. Water storage and delivery are not subject to administrative modification because they are fixed by law and because flood control is essential for

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Scope and Organization of the GCES 27 TABLE 2.2 Resources Potentially Affected by Variations in the Operation of Glen Canyon Dam 1. Recreation A. Trout Fishing B. Rafting 11. Hydropower and hydropower revenues Ill. Biotic communities A. Aquatic communities (including endangered species) B. Riparian communities (including endangered species) IV. Sites of cultural or archaeological significance V. Nonuse values protection of the dam. Marketing of hydropower is required by law but is flexible operationally and thus confers on management the responsibility to assess the relationship between power production and the value or welfare of other resources. GCES was the first systematic attempt to describe and quantify the effect of dam operations on resources other than hydropower. GCES did not initially make simultaneous commitments to studies of all the resources potentially affected by operations. It focused at first on sed- iment supply and sediment dynamics (see Chapter 5), which are important for recreation (Chapter 7) and for fishes, and on biotic communities, with particular emphasis on endangered species (Chapter 6~. GCES was slow to acknowledge the relevance of cultural studies (Chapter 8) and initially ex- cluded studies of power production (Chapter 9) because the BOR and WAPA began with the assumption that the dam would continue to be managed for production of maximum power revenues. Even after the BOR accepted the modification of operating regimes for the benefit of other resources, with the loss of some power revenues, it resisted open (i.e., involving external independent analysis) studies of power production because studies of power had been internal to the BOR and WAPA since operation of the dam began. The EIS on power production did what GCES could not do initially, which was to require an open and complete study of power production in relation to dam operations. This was ultimately

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28 River Resource Management in the Grand Canyon an extremely important contribution to the understanding of resources in relation to operations. Without it, GCES would have been far less valuable because it would not have led to reliable quantitative estimates of power re- venue losses in relation to operational changes offering environmental be- nefits. As shown by Chapter 9, studies of power and power revenue proved to be far more controversial and problematic than originally expected. Models in use by WAPA at the onset of the studies projected costs that were un- justifiably high and even outrageous for modest operational changes (NRC, 1991~. The formation of a study group involving not only the BOR and WAPA but also environmentally oriented experts and independent consultants ul- timately produced by consensus a very different view of power production revenues. Another resource of interest that remained long unstudied is shown in Table 2.2 as nonuse values. As described in Chapter 7, nonuse value refers to that aspect of an environmental resource that derives from appreciation of a particular state of the resource by those who are not using it. Although relatively new, this is now an acknowledged dimension of comprehensive environmental studies (Chapter 7~. Nonuse value seems particularly relevant in the case of the Grand Canyon because of the high aesthetic and intangible values attached to the region nationally and internationally and by Native American tribes (the BOR received 33,000 comments on the draft EIS for operation of Glen Canyon Dam). Even so, or perhaps for this very reason, the bureau long resisted inclusion of nonuse value studies but in 1995 acceded to them as an addendum to the EIS. Not surprisingly, the studies of nonuse value, which were conducted by an independent consultant with admirable use of peer review and outside critique, produced estimates of nonuse value that vastly exceed all tangible values, including power production revenues (Chapter 7~. While the administrative response to this information is yet to be resolved, the information itself is clearly warranted as a component of GCES. The Ecosystem Perspective In 1987 the NRC committee was concerned about evidence that GCES lacked an appropriate conceptual framework around which to build its study and prioritize its expenditures. Phase 11 of GCES, however, embraced the ecosystem concept as a basis for planning. This advance was very impor- tant, but various factors prevented its full execution.

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Scope and Organization of the GCES 29 The ecosystem concept, which now has been widely embraced by federal agencies under the heading of ecosystem management (Lewis, 1994), is essentially a substitute for using a list of issues or resources in organizing environmental studies. While such lists continue to be important in all en- vironmental studies, including those of the Colorado River, the study plan must take into account the relationships among physical, chemical, biotic, and anthropogenic components of the environment. The ecosystem concept acknowledges that management of environmental systems operates within a framework whose components are functionally connected. Following NRC criticism (NRC, 1987) that the GCES study plan was haphazard and diffuse, GCES managers adopted an explicit ecosystem frameworkforthe design and operation of studies. This move was reinforced by the appointment of a senior scientist, also in response to NRC recom- mendations. One purpose of appointing the senior scientist was to add expertise in ecosystem analysis to the GCES. The most common way of applying the ecosystem concept to a particular location is by diagrammatic representation of the system. In the process of constructing such a diagram, analysts of the system must acknowledge in a comprehensive way the interactions that are likely to be critical to an un- derstanding of the problems at hand. The GCES produced its ecosystem diagram (Figure 2.1) when its pro- gram was already well under way. Critique of the GCES ecosystem diagram is possible, especially given the hindsight provided by a decade of GCES. On the whole, however, the diagram captures in a reasonable way the major components of the system and their relationships, especially with regard to the controversies that motivated GCES. By the time the diagram had been produced and refined, however, disposition of GCES resources was dictated either by precedentfrom earlierGCES studies orbylegal oradministrativefiat (see below). Thus, GCES did not provide an ideal test of utility for the ecosystem diagram. As a test of the importance of the ecosystem diagram to GCES, in 1994 the NRC committee inquired about GCES support for each of the ecosystem components and causal connections shown in the diagram. This exercise demonstrated that a number of the significant causal connections shown in the diagram were not under study by GCES. In this sense, GCES was only incidentally an ecosystem study, even though it did ultimately cover quite a number of components and connections. Flaws in the diagram are brought out in the chapters of this report on individual components of the system. The primary flaw related to the ecosystem concept for GCES was, how

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Scope and Organization of the GCES 31 ever, practical rather than conceptual. The scope of work for GCES, and the priorities for GCES investments, were ultimately defined almost entirely by the list of resources shown in Table 2.2. The weakness of this approach is that each resource has specific advocates, which may be agencies, public groups, or commercial interests. Advocacy thus becomes a key factor influencing the design of studies, and the essential connection to operations is lost, as is the concept of ecosystem analysis. For example, GCES resources were used for studies of bald eagles, which began to populate the Grand Canyon seasonally in considerable numbers during the 1 980s. There is at best a very weak connection, however, between the welfare of the bald eagle population and any conceivable variant on operations of the Glen Canyon Dam. Many examples, accounting ul- timately for as much as half of the GCES budget, can be traced to this type of boundary expansion of GCES. The reasons for boundary expansion can be found mainly in forces associated with law and politics. The GCES was never completely driven by an ecosystem model. Rather, its focus changed over time as various external constituencies were able to convince Congress and the Department of the Interiorto intervene in GCES and the EIS process. OTHER INFLUENCES ON THE SCOPE OF GCES Administrative Policy The initial definition of scope for GCES was almost purely administrative in the sense that it did not reflect the geographic or conceptual extent of effects that might reasonably be connected with dam operations. The BOR directed GCES to deal with the Colorado River immediately below Glen Canyon Dam and to consider only changes in operations that would be neu- tral with respect to power revenues. One objective of the BOR was to contain the cost of GCES. Another factor, however, may have been the desire of the BOR and of WAPA with which BOR necessarily has a close working rela- tionship, to reduce the likelihood of challenges to the principle that dam operations can be changed in ways that reduce power revenues, if en- vironmental benefits accrue from such changes. The initial administrative definition of scope was unrealistic. The flexibility of dam operations within the constraint of maximum power revenues is so small that studies restricted to this scope would be of limited use. Expansion of GCES was probably inevitable given the range of interests

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~2 River Resource Management in the Grand Canyon and political forces that came to bear, especially through the EIS, on the BOR. The NRC committee played an important role in questioning the premisethatflexibility of operations could tee viewed onlywithinthe constraint of maximum power production. To its credit, the BOR ultimatelyaccepted the advisability of viewing the scope of GCES much more broadly and thus more realistically. By the end of GCES, the initial unrealistic constraints on its scope had disappeared. In Rs last several years GCES came under the influence of factors that were not always directly related to the effects of dam operations. GCES expanded geographically to the upper end of Lake Powell, up the tributary canyons, above the present high-water mark, and out to tribal lands on the rim. A rational administrative approach would have been to ask, as a means of limiting scope, whether a given type of study or inquiry could reasonably be connected to variations in the operation of Glen Canyon Dam. Instead, the BOR adopted the more expedient principle of simply setting an annual dollar cap (often a quite generous one, extending to as much as $12 million per year at its peak) on the GCES and essentially ignoring the necessity of con- nections between scope and the clam's operation. As explained below, several factors contributed to this change in administrative policy. Law and Politics In several instances the scope of GCES was affected by federal laws that extended the program well beyond the connections between resources and dam operations. When GCES began, no EIS was in progress orwas planned. When Interior Secretary Lujan invoked the National Environmental Policy Act (NE PA) by calling for two ElSs (one for operations and one for power production), the scope of GCES was affected. The NEPA checklist for EIS production called repeatedlyfor information that could only come from GCES and thus modified GCES scope and scheduling. For example, studies of archaeological sites by the National Park Service were arguably far more elaborate than they needed to be if defined by the original objectives of GCES rather than the more inclusive requirements of the EIS, which were augmented by the Park Service's interest in obtaining an archaeological inventory with monies originating outside its budget. As explained more fully in Chapter 10, individual agencies used their mission statements as guiding principles in defining research objectives ra- ther than the specific needs of GCES. The research conducted by a myriad

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Scope and Organization of the GCES 33 of cooperators under the GCES umbrella would have been more effective if all the parties involved had devised a system to focus on resources on the stated purpose of GCES. Much of the information that was collected outside the obvious scope of GCES is scientifically sound and will prove useful in other contexts, but the inability of the "cooperators" (Table 2.3) to devise a system for focusing resources on the stated purpose of GCES was a remarkable and consistent feature of the program, and resulted in great expansion of expenditures and diffusion of focus. Because federal laws and high-level politics were involved in these processes, it is impossible to fault individuals and certainly not the primary organizers of GCES, who to a large extent were buffeted by forces well beyond their control. In 1987 the NRC committee criticized the GCES for failing to derive and follow a specific plan that, in turn, would be linked to alternative possibilities for operating Glen Canyon Dam. While the committee was quite successful in encouraging a badly needed expansion in the scope of GCES during the mid-1 980s, it was later much less successful in trying to move GCES toward greater focus of resources on a predetermined plan and exclusion of expenditures that could not be justified by the objectives of the program. ORGANIZATION OF THE STUDY GROUP By the early 1980s, when GCES began, patterns for the use of power revenue from Glen Canyon Dam had been in place for almost 20 years. The intrusion of GCES as a new demand on the power revenue stream was vehemently and openly opposed by WAPA, which argued that power re- venues ($50 million to $100 million per year, depending on the market for electricity) should not be used for this purpose. Nevertheless, roughly 10 percent of power revenues was used for GCES over its 13-year life. As a result of the Grand Canyon Protection Act of 1992 (see Chapter 3), long-term monitoring, which is the successor to GCES, will constitute an expense that is reimbursable to the U.S. Treasury after the EIS Record of Decision is issued. Thus, future costs of environmental studies below Glen Canyon Dam will be borne by U.S. taxpayers at large, rather than by users of power from Glen Canyon Dam. Although the GCES was initiated and managed by the BOR, it involved extensive participation by other federal and state agencies and by Native American tribes. Decisions about the course of GCES were made by the BOR manager but typically with strong advice from the cooperators. The

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Scope and Organization of the GCES 35 cooperators not only provided advice on the course of study but also re- ceived and expended GCES monies or served as conduits for GCES con- tracts (Table 2.3~. The organizational structure of GCES contained several weaknesses that became increasingly evident over its history. While the BOR should be credited with assigning a full-time position to the management of GCES and placing the GCES budget in principle at the disposal of the project manager, the BOR failed to reinforce the independence and effectiveness of project management. The immediate reporting hierarchy ofthe project manager was initially critical of the fundamental basis for GCES and particularly of its expansion to a realistic geographic and conceptual scope. Although this situation changed during the last years of GCES, it handicapped the early phases of project development. Equally important was the level of admin- istrative placement of the GCES management, which reported to a district office of the BOR. The BOR is an agency of the U.S. Department of Interior, as are the cooperators, with the exception of the Native American tribes and the Arizona Game and Fish Department. Thus, the GCES project manager, who was reporting to a district administrator inside one of the agencies among the cooperators, was outranked by most of the individuals who made up the cooperating group. The NRC committee perceived this difficulty early in GCES and recommended in 1987 (NRC, 1987) that GCES Phase 11 be or ganized in such a way that the project manager would report to an Assistant Secretary of the Interior, thus being connected to the administrative umbrella over all of the federal cooperators. This change was not made. The effect of administrative flaws on GCES is difficult to evaluate. Subsequent chapters of this report will show, however, that GCES suffered, notwithstanding energetic and adaptable leadership, from a consistent inability to exercise control over the cooperators for the benefit of general project objectives. In practical terms the project manager was unable to withhold funds from agencies that failed to meet contractual obligations and had difficulty in confining or directing the scope along lines that were contrary to those preferred by individual cooperators. CONCLUSIONS The initial design of GCES was severely flawed in definition of scope and in organization for a variety of reasons. Over several years, through adjust

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36 River Resource Management in the Grand Canyon meets made primarily through the response of the GCES management and the BOR to outside comment and critique, many of the flaws were reduced or eliminated. Thus, the scope and organizational strength of GCES im- proved over the Ice of the project. If these institutional adjustments can be carried into other projects of the BOR or other management agencies, future environmental projects will be less costly and more effective in meeting their goals. While GCES improved in a number of important respects over its history, its effectiveness was impaired even in its latest phases by a number of unsolved problems related to scope and organization. These include es- pecially the internalization of expenditures among the federal cooperators, the inability of the project manager to exercise free authority over critical decisions because of the administrative structure of the project, and the introduction of ancillary objectives through law or ad ministrative fiat that were not necessarily relevant to the project's objectives. The GCES has shown that federally sponsored environmental assessment should be organized around three sets of considerations: 1) a list of re- sources, 2) a list of management options, and 3) the ecosystem concept. Omission or incomplete treatment of any of these three considerations will greatly impair the usefulness of the final outcome of environmental ass- essment. Furthermore, given that large, federal environmental studies will in the future increasingly involve multiple federal agencies with differing missions and priorities, the project manager for any large environmental assessment must be grantecl, for the benefit of the project, sufficient independence and authority over financial resources to override undue influence by individual agencies. The GCES experience shows that concentration of authority in the project leadership, and initial commitment to complete consideration of all management options and resources, including those that may be out of favor or controversial, will be the most likely strategies to conserve resources and produce outcomes useful to management. REFERENCES Bureau of Reclamation. 1995. Operation of Glen Canyon Dam. Final Environmental Impact Statement. U.S. Department of the Interior, Wash- ington, D.C.

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Scope anal Organization of the GOES 37 Lewis, W.M., fir. 1994. The ecological sciences and the public domain. University of Colorado Law Review 65:279-292. National Research Council. 1987. River and Dam Management: A Review of the Bureau of Reclamation's Glen Canyon Environmental Studies. Washington, D.C.: National Academy Press. National Research Council. 1991. Colorado River Ecology and Dam Man- agement. Washington, D.C.: National Academy Press.