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3

General Comments

STYLE AND PRESENTATION

The style and presentation of the plan would benefit from extensive revision. Weaknesses in the present draft include: (1) poor writing, (2) weak logical coherence, and (3) lack of specificity. The mechanics of good writing are much more than a matter of cosmetics; they interfere with clear presentation of the monitoring plan.

Poor writing is responsible for much confusion in the present draft. The writing is too often convoluted, syntactically difficult or incorrect, and often employs words in a technical context that have no precise technical meaning. Examples of poor usage include such words or phrases as “attribute inputs,” “visitations,” “statistical reliability,” “value evaluation,” and many others.

A second problem is weakness in the logical thread that should connect monitoring objectives, needs for information, and protocols for data collection. These three elements are present in the draft, but they do not follow as necessary to make a clear argument for the collection of specific kinds of data. The use of addenda in this plan is ineffective, fragmenting the plan and separating items that should be together. The information within the addenda should be integrated throughout the body of the plan.

Perhaps the most serious problem of all is the failure of the monitoring plan to be sufficiently specific. In some cases, numbers of sites and kinds of measurements are listed, but even so must be extracted from the narrative. In other cases, sites, frequencies, and even variables to be monitored are left to other decisionmakers or dismissed in a general way. Throughout the text, subjunctive statements stand in place of declarations or assertions; priorities are not stated forcefully. Even the introduction is not sufficiently positive or assertive to set the stage for firm recommendations.

The monitoring plan should set forth a specific blueprint for collection of data. The contributors to the plan have benefited from over a decade of experience with



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Review of the Draft Federal Long-Term Monitoring Plan for the Colorado River below Glen Canyon Dam 3 General Comments STYLE AND PRESENTATION The style and presentation of the plan would benefit from extensive revision. Weaknesses in the present draft include: (1) poor writing, (2) weak logical coherence, and (3) lack of specificity. The mechanics of good writing are much more than a matter of cosmetics; they interfere with clear presentation of the monitoring plan. Poor writing is responsible for much confusion in the present draft. The writing is too often convoluted, syntactically difficult or incorrect, and often employs words in a technical context that have no precise technical meaning. Examples of poor usage include such words or phrases as “attribute inputs,” “visitations,” “statistical reliability,” “value evaluation,” and many others. A second problem is weakness in the logical thread that should connect monitoring objectives, needs for information, and protocols for data collection. These three elements are present in the draft, but they do not follow as necessary to make a clear argument for the collection of specific kinds of data. The use of addenda in this plan is ineffective, fragmenting the plan and separating items that should be together. The information within the addenda should be integrated throughout the body of the plan. Perhaps the most serious problem of all is the failure of the monitoring plan to be sufficiently specific. In some cases, numbers of sites and kinds of measurements are listed, but even so must be extracted from the narrative. In other cases, sites, frequencies, and even variables to be monitored are left to other decisionmakers or dismissed in a general way. Throughout the text, subjunctive statements stand in place of declarations or assertions; priorities are not stated forcefully. Even the introduction is not sufficiently positive or assertive to set the stage for firm recommendations. The monitoring plan should set forth a specific blueprint for collection of data. The contributors to the plan have benefited from over a decade of experience with

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Review of the Draft Federal Long-Term Monitoring Plan for the Colorado River below Glen Canyon Dam GCES studies and from more than a year of consultation and study of long-term monitoring strategies. At this point they should formulate a very explicit plan. If they do not, there is little hope that individuals less familiar with the environment and with the requirements for information will do so successfully at a later date. The long-term monitoring plan is a very important document. It will be used by the Bureau of Reclamation and other agencies, and perhaps by other countries, as a prominent example of a monitoring program for rivers downstream from dams. It should be a model of clarity and it should be explicit and definite in its recommendations. The plan should be understandable not only to specialists, but also to any educated person, and should be easily translatable into an actual data collection program. The NRC committee recommends that the plan be rewritten with emphasis on clarity of expression, logical consistency, and specificity of recommendations. Although the plan may legitimately allow latitude for minor adjustments in data collection, it should not defer judgment on monitoring. The committee also recognizes that the plan, while requiring specificity, must allow for later changes. A clear process must be established for making these changes in long-term monitoring as new information indicates that some monitoring components no longer are needed and that other data not previously collected are needed. The revised plan should include a comprehensive table that lists by category each kind of information that will be collected as part of the long-term monitoring program, as well as the frequency of data collection and the number and location of sites. In addition, the revised plan should include maps showing the geomorphic reaches that are referenced in the plan, the locations of gages, and the monitoring sites mentioned in the text. OBJECTIVES OF MONITORING Many sections of the monitoring plan contain a paragraph that gives broad justification for the long-term collection of data. This justification is consistently based on gaging the validity of the preferred alternative for dam operations. This statement of objectives is too narrow. The long-term monitoring program in the Grand Canyon, as viewed from the perspective of the 1992 Grand Canyon Protection Act, is not specifically geared to the draft EIS or to present operating regimes. Its purpose should be to produce a constant flow of reliable basic information that will be useful for assessing any environmental change in the Grand Canyon between Lake Powell and Lake Mead under any operating regime, whether actual or hypothetical. To tie the plan to the draft EIS is overly restrictive. The committee believes that long-term monitoring is critical for adaptive management and that the plan is an indispensable part of the management of the Dam.

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Review of the Draft Federal Long-Term Monitoring Plan for the Colorado River below Glen Canyon Dam DISTINCTIONS BETWEEN MONITORING AND RESEARCH In its opening sections, the long-term monitoring plan draws distinctions between monitoring and research. These distinctions are correctly stated, but they should be sharpened. The monitoring plan should state explicitly that a continuously funded research program is an important complement to the long-term monitoring program. The plan needs to explain that monitoring is likely to produce unexpected results that create a need for research, and that new research might dictate changes in monitoring. The plan should indicate the approximate size of a continuous research effort to serve as an adequate complement to the long-term program. EMPHASIS ON NON-INVASIVE METHODS The plan should deal more explicitly with the conflict between: (1) the need to monitor the canyon ecosystems closely, and (2) the need to preserve the systems in as natural a state as possible. While it is true that the river is highly regulated, it flows through a portion of the national park that is managed as a wilderness area. According to the 1964 Wilderness Act, works of man shall not be visible, and evidence of human activities will not be apparent. The monitoring plan should deal directly with this conflict. The monitoring plan should specifically state a commitment to: (1) taking samples in sufficient quantity to meet monitoring objectives but not in excessive numbers; (2) monitoring processes in the canyon by remote sensing wherever possible; (3) camouflaging recording devices and physical equipment so that they are not disruptive to the visual landscape; (4) avoiding use of sensors or measuring devices likely to be encountered by recreational users of the canyon; and, (5) avoiding repetitive use of access routes that may develop into new trails. The monitoring plan should also point out that the objective of minimal visibility does not mean the elimination of scientific monitoring, measurement, and collection of data. These activities are required by the 1992 Grand Canyon Protection Act, and are essential components of the Bureau of Reclamation's plan to operate Glen Canyon Dam in a fashion that protects the resources of Grand Canyon. ADMINISTRATION, CONTRACTING, AND COST The monitoring plan does not discuss administrative strategies, contracting, or cost. The committee believes that these omissions will undermine the success of the long-term monitoring program. Administration and reporting authority for the long-term monitoring program will be critical in determining its quality, stability, and cost-effectiveness. Administrative

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Review of the Draft Federal Long-Term Monitoring Plan for the Colorado River below Glen Canyon Dam models that are under consideration are described only superficially in the plan, but it appears to be based upon a committee of representatives from federal cooperators. The NRC committee does not believe that this is an effective scheme for management of a long-term monitoring program. The cooperators should provide advice to the program, but should not control it. The program should be administered independently of any specific agency or agency cluster; it should report directly to, and have its budget determined by, a higher authority because the program involves the resources and responsibilities of multiple agencies of the Interior Department, the Department of Energy, the EPA, and the Indian tribes. Independence for the long-term monitoring program is essential if the program is to remain stable through changes in management philosophies, conflicts among agencies, and fluctuating degrees of enthusiasm for long-term monitoring. The long-term monitoring program should take into account not only reviews and guidance from cooperators, but also reviews and guidance from specialists outside the cooperating agencies. In addition, the long-term monitoring program will probably maximize its cost efficiency and its flexibility by restricting its operations to issuance of contracts, archiving of data, and coordination of administrative and scientific review, rather than employment of a monitoring staff. An objective process needs to be specified for review and approval of proposed changes in the long-term monitoring program. Changes will be desirable as the program matures and as scientific methodologies and understanding evolve. The process for making changes needs to be protected from agency politics, insofar as possible, by use of an outside review panel to evaluate proposed changes, and through administrative independence of the program. Contracting policies are also important to the success and efficiency of the monitoring program, but are not addressed in the present plan. The committee's experience with GCES indicates that cooperating agencies have a strong tendency to contract internally, or to recognize reciprocal contracting rights that reflect management responsibilities for the particular resource being monitored. While this is appropriate and efficient in some instances, in others it leads to a waste of resources. Truly competitive contracting arrangements should be a feature of the long-term monitoring program, and should extend beyond the cooperating agencies to any entity, public or private, that would be well qualified for the work. In the committee's view, the administrators of the monitoring program should establish an agreement with the cooperating agencies, with help from the Interior Department as necessary, stating that contracts related to long-term monitoring not be held captive for reasons having to do with permits, authorization of access, or use of publicly owned equipment such as gages. Free exercise of contracting authority on the part of the long-term monitoring administrators will avoid the development of entitlements that in turn could produce great cost inefficiencies and programmatic inflexibility.

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Review of the Draft Federal Long-Term Monitoring Plan for the Colorado River below Glen Canyon Dam The plan makes no estimate of cost. Specific estimates of cost should be tabulated for each type of data collection. In the absence of any information on cost, the tendency may be for administrators to allocate insufficient money for the long-term monitoring program. If the size of the program is dictated by an arbitrary allocation, much of the effort that has been invested in defining minimum boundaries for the program will have been wasted, and the program may become ineffective.