Review of the Draft Federal Long-Term Monitoring Plan for the Colorado River below Glen Canyon Dam (1994)

The plan should be revised extensively and rewritten to improve clarity, logical cohesion, and degree of specificity with which monitoring requirements are described. The revisions should also take into account the following recommendations:

1. The plan should include a comprehensive table that lists by category the type of information to be collected, as well as the frequency of data collection and the number and location of sites.

2. The objectives of monitoring should be modified to encompass not only a study of responses to the currently preferred alternative for operation of the Dam, but also responses to other hypothetical or actual operations of Glen Canyon Dam and to environmental changes occurring through other causes within the scope of dam operations.

3. A number of measurements that are to be made seasonally or quarterly may not be useful because of the long gap between measurements. The frequency of these measurements should be increased.

4. The plan should include a more explicit treatment of the relationship between environmental monitoring and environmental research, and should make specific recommendations on a research program that would complement monitoring.

5. The plan should specify that the long-term monitoring program will assume direct responsibility in perpetuity for the acquisition of specific kinds of information; this responsibility should not be delegated to agencies, although use of data from agencies should be possible if the data meet requirements set by the long-term monitoring program.

6. The plan should call for greater emphasis on non-invasive methods for studying the Colorado River; permanent cableways should be removed.

7. The plan should include proposals for administration of the long-term monitoring program and for review and control of its operations. It should also deal explicitly with contracting mechanisms and with estimated costs. Proposals for administration and contracting should take into account the advantages of administrative independence and the importance of stability for the monitoring program, as well as the advantages in cost efficiency and programmatic quality that derive from open contracting procedures.