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Review Procedures for Water Resources Project Planning 7 Recommendations The Panel on Peer Review provides the following recommendations for improving review procedures of U.S. Army Corps of Engineers water resources planning studies and projects: The Corps’ more complex planning studies should be subjected to independent review by objective, expert panels. Reviewers should not be selected by the Corps, and they should not be employed by the Corps. Reviews should be overseen by an organization independent of the Corps. Examples of organizations that might lead these independent reviews include professional science or engineering societies, the National Academies, and the National Academy for Public Administration. Responsibility for these external reviews could also be delegated to an independent federal oversight group, with the Department of Energy’s Defense Nuclear Facility Safety Board serving as a possible model. Congress should direct the Corps to establish an Administrative Group for Project Review (AGPR) and should provide the necessary resources for its operations. The AGPR should be housed in either the Office of the Assistant Secretary of the Army for Civil Works or in the Office of the Chief of Engineers. The AGPR’s roles should include determining whether a Corps planning study should be reviewed and the appropriate level of independence of review. The AGPR should not conduct reviews itself. The Administrative Group for Project Review should provide a summary document of the planning study at hand to the review panel. The Administrative Group for Project Review should produce a document that clearly explains the Corps’ review procedures. These pro-
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Review Procedures for Water Resources Project Planning cedures should be viewed as flexible and should evolve over time as the Corps’ review process matures. The AGPR should periodically update this document. The decision regarding the degree of the review’s independence should be open to review upon petition by interested parties. The Administration (perhaps from the director of the OMB) and Congress (through congressional resolution or other legislative action, but not simply through committee language) should also be able to request a review of a Corps planning study. The review process should take no longer than 60 days. A Review Advisory Board (RAB) should be established to provide periodic review of the Administrative Group for Project Review’s mandate, structure, and decision-making processes. It should advise upon the processes for selecting reviewers and independent external review bodies. The Review Advisory Board should assess processes for ensuring consistency, thoroughness, and timeliness of reviews, and it should consider both past studies and prospective studies and projects. It should periodically evaluate the scopes of review proposed by the Advisory Group for Project Review, and it should review a sample of summary documents prepared by the AGPR to ensure their clarity and comprehensiveness. The functions of the Review Advisory Board may need to be established within a body that has a more comprehensive review mandate of Corps programs. The Corps of Engineers should be included at some level within all reviews. Corps staff will be intimately involved with internal reviews, and external reviews will ultimately be more effective if the review panel maintains communication with the Corps during the review. This communication, which should not compromise the review’s independence, can help the review panel understand the Corps’ planning assumptions and methods, as well as the practical implications of the review panel’s findings and recommendations. The Administrative Group for Project Review should broker this communication between the Corps and a review panel, as well as communication between the panel and relevant federal agencies, interest groups, and the public. Review results should be presented to the Chief of Engineers before a final decision on a planning study is made. Results should be available to the public. The report from the review panel should be included in the Corps’ planning study submitted to Congress. The Chief of Engineers should respond in writing to each key point in the report of a review panel. The Chief should either agree with a point and explain how it will be incorporated into the planning study or project, or the point should be rebutted with an explanation of why the
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Review Procedures for Water Resources Project Planning Corps is choosing to reject it. In the event that review is initiated in a planning study’s early stages, the results of the review should be submitted to the Corps’ District Engineer. The District Engineer should be responsible for preparing a written document that explains how the Corps intends to incorporate the review results into the study. Reviews should be initiated early enough in the Corps’ study process so that review results can be meaningfully incorporated into the planning study or project design. With controversial studies, the Corps should ordinarily initiate review early in the feasibility, reoperations, or other study under review. When review is initiated early in a planning study, results of the review should be submitted to the Corps’ District Engineer. In controversial studies, reviews should be conducted at different stages of the planning study. It s important that review panels not become too strongly attached to their reports and become defenders of their recommendations. The composition of review panels may thus need to be changed during the course of a planning study or project, especially lengthier ones. To effect some standardization across review panels, some panelists should be identified to serve on multiple panels. Internal review panels should usually consist of a balance in the number of Corps of Engineers professional staff and experts independent of the Corps. In external reviews, the Corps may submit nominees to serve as reviewers, but the Corps should not select the reviewers. External review panels should consist only of experts independent of the Corps. Reviews should be conducted to identify, explain, and comment upon assumptions that underlie economic, engineering, and environmental analyses, as well as to evaluate the soundness of models and planning methods. A review panel should be given the flexibility to bring important issues to the attention of decision makers. Review panels should be able to evaluate whether the interpretations of analysis and the conclusions based on analysis are reasonable. However, review panels should be instructed to not present a final judgment on whether a project should be constructed or whether a particular operations plan should be implemented, as the Corps of Engineers is ultimately responsible for this final decision. Congress should provide resources to the Secretary of the Army to help implement this report’s recommendations directed toward improving review procedures within the Corps.
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