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GCMRC participation in Ad Hoc Groups
GCMRC is the only AMP element that is expected to serve on every ad hoc committee
appointed by the TWG or the AMWG. While the GCMRC recognizes that it must be an active
participant on these ad hoc committees, the situation has at times put overwhelming pressure
on GCMRC staff due to workload issues. GCMRC does, in fact, want to be a full partner with
the AMP participants, but these participants must also be sensitive to GCMRC time
limitations.
As a general rule, GCMRC will participate in all AMWG, TWG, and Ad Hoc Committee meetings, as
appropriate. In the event this is not possible, GCMRC will so communicate to the Chair of the
relevant committee in advance of the meeting.
A common understanding of and sensitivity to the workload issue is vital to an efficient and effective
AMP process. The 1-year schedule referred to in Issue #5, which shows the essential items that the
AMP must do each year, will assist in managing and planning for the GCMRC workload. Any
additional task will involve a decision as to whether it can be done in the timeframe requested by
AMWG.
In addition, the process described in Issue #6, which allows the GCMRC to resolve concerns about
their workload, will ameliorate this problem.
As noted above, when TWG is given an assignment from AMWG, the GCMRC would also usually be
involved. Therefore, an AMWG action to a recommendation to the Secretary may be needed to
secure GCMRC involvement.
GCMRC focus and deliverables
GCMRC efforts will focus on the most important work products. These may include fieldwork,
contracting, budget, SCORE reports, and AMWG/TWG briefings. GCMRC’s activities and
deliverables are defined in the MRP and BWP. GCMRC will develop a report for each project in the
BWP at the end of each fiscal year. This report will document accomplishments and expenditures, as
well as shortfalls, with recommendations for change.
GCMRC workload
When requesting or recommending GCMRC take on a task, the AMP needs to be realistic in
setting deadlines and should more carefully consider the work capacity and timeframe
involved. In addition, from time to time, clarity of assignment is an issue, when GCMRC feels
they have delivered a product on time and AMWG or TWG may say they are late because the
product is not what they thought they requested.
GCMRC budget latitude and accountability
Some feel the GCMRC does not want to be responsive to the needs of the AMP. There are no
clearly defined limits of flexibility on GCMRC’s management of science projects without
going back to AMWG or DOI for approval. Some AMP members feel that GCMRC appears to
have made unilateral changes in approved documents, work plans, and budgets without
communicating with AMWG, which has reduced the level of trust between AMP members and
GCMRC.
It is imperative to the success of the AMP that a positive, affirmative, and accountable relationship
exists between GCMRC and the AMWG. One of the challenges presented in this regard is the fact
that the AMWG only meets two to three times per year and therefore cannot always address issues
quickly, including urgent budgetary issues. When GCMRC makes needed budget adjustments,
AMWG might perceive such actions as constituting unilateral and unauthorized changes by GCMRC
to approved budgets and research plans.
The GCMRC will give periodic updates on its operations and budget to the Secretary’s Designee,
AMWG, and TWG, including an annual accomplishments report, semi-annual budget reports, and
reports on projects that have been deferred or significantly delayed. The BWP will include
contingency projects that will be funded if surplus funds arise. GCMRC has the latitude to make
budget adjustments of up to 5 percent of its total budget to accomplish work specified in the BWP.
No new AMP projects will be implemented by GCMRC or Reclamation without first consulting with the
TWG chair and vice-chair and the Secretary’s Designee. The Secretary’s Designee will determine
whether consultation with the AMWG is needed.
Contracting
The AMWG is concerned that GCMRC has drifted in recent years from full compliance with
the original and long-standing agreement that it use an open, competitive process to award
research contracts or to enter into cooperative or interagency agreements for scientific work
in support of the AMP. GCMRC acknowledges that competitive procedures were not used in
the recent mechanical removal and experimental high flow studies due to time and logistical
constraints arising from the time it took to complete the environmental compliance in
juxtaposition with when work had to be underway in the field. This was not intended to be a
repudiation or abandonment of the long-term agreement to openly compete much of the
scientific work of the AMP.
The foundational documents provide some direction, and some flexibility, to GCMRC with regard to
contracting:
The following specific duties would be assigned to the Monitoring and Research
Center:...Administer research proposals through a competitive contract process, as appropriate
(Department of the Interior, 1995, p. 37).
The Center ... shall be composed of a small staff of administrative and scientific personnel, who
will be detailed from other Department bureaus. The research program is proposed to be
conducted through an open call proposal and (or) contract process, including a competitive
request for proposals, with Federal and state agencies, universities, the private sector, and Native
American tribes which will result in the selection of research projects based on scientific merit and
cost. Required elements of the monitoring program may be proposed as an on-going
responsibility of the USGS after an open decision-making process (Deputy Assistant Secretary
for Water and Science, 1995, p. 2).
The GCMRC shall be composed of an appropriately sized staff of administrative and scientific
personnel with relevant scientific and technical expertise... Monitoring and research activities
Report and Recommendations from the Roles Ad Hoc Group to the Secretary’s Designee Page 22
conducted by GCMRC will be implemented primarily through a competitive request for proposals
with Federal and state agencies, universities, the private sector, and Native American tribes. The
successful proposals shall be selected on the basis of advice provided by an independent
external scientific peer-review (Schaefer, 2000, p. 2).
Other functions of the Grand Canyon Monitoring and Research Center are ... Develop research
designs and proposals for implementing (by the Grand Canyon Monitoring and Research Center
or its contractors) monitoring and research activities in support of information needs; ... (Glen
Canyon Dam AMWG, 2002, p. 5).
Bob Snow (Washington Solicitor’s Office) ... reviewed his understanding of the concerns ... [to
wit,] if the procurement requirements had changed from using different entities to do work in the
Grand Canyon towards a concentration of research being done by GCMRC. Bob said the
Department has an opportunity to either avail itself of its in-house resources or ask external
groups, cooperators, etc., to take on those tasks. The fact that there is an ongoing FACA
process does not change the fundamental nature of being able to task USGS within their organic
statutory authority to take on certain studies (Glen Canyon Dam AMWG, 2004, p. 10).
The use of contractors versus in-house staff by GCMRC is clarified in the Strategic Science Plan that
was approved by the AMWG on December 5, 2006:
Contractors and cooperators will be utilized to conduct a large measure of the field work and work
collaboratively with GCMRC on data analysis, synthesis, and publication. GCMRC scientists will
be engaged in the implementation of field research and monitoring when in-house staff with the
appropriate expertise is available and their use is cost effective. In every case the USGS will hold
its own proposals to the same level of rigorous outside peer review as all others.
Several land and resources management agencies including National Park Service (NPS), Fish and
Wildlife Service (FWS), Arizona Game and Fish Department (AGFD), and the Tribes have statutory or
regulatory responsibilities for long-term management of resources in the Grand Canyon. In addition,
USGS, the parent organization of GCMRC, includes many leading experts in river science.
Collectively, these agencies/entities have technical skills and capabilities that can assist in conducting
some of the work being recommended by the AMP. These entities are an integral part of several
resource monitoring efforts, including monitoring of humpback chub and other native fishes, rainbow
trout and other nonnative fishes, hydrology and sediment, archaeological resources, and traditional
cultural properties. Having these agencies/entities as active partners in the AMP science program
helps meet their statutory responsibilities and facilitates the integration of the scientific information
into management processes and decisions. The services of these agencies and entities are
generally secured through interagency and cooperative agreements, rather than through competitive
RFPs.
No matter who carries out the work of the AMP, Protocol Evaluation Panels (PEPs) are used to
provide an independent scientific perspective on the efficacy of all major elements of the science
program, including the scope, objectives, methods, past performance, and recommended future
direction of science projects. PEP reviews are used to help design new research programs and to
evaluate the ongoing work of established projects. In addition, peer reviews of proposals and
deliverables provide independent review of specific AMP scientific efforts to ensure high scientific
quality.
The purpose of open competition through RFPs is to promote cost effectiveness, expanded breadth
of ideas, optimal scientific design, and highest levels of scientific expertise. However, this process
takes more time, effort, and cost to achieve these objectives. The scientific protocols as described
above will contribute to accomplishing many of the same scientific objectives.
The most cost effective mechanisms will be used to accomplish work. In general, GCMRC and
Reclamation will prepare RFPs and use an open, competitive process for awarding funding for new
research projects or new initiatives (e.g., food base monitoring and research, near shore ecology).
For other projects, limited competition, and sole-source contracts in accordance with Federal
Acquisition Regulations may be used IF cooperators agree to (a) conduct the required work at a fair
cost, verified through market research, (b) meet the required technical specifications as determined
by GCMRC and implement PEP and SA recommendations accepted by the AMWG and approved by
the Secretary, and (c) comply with independent peer review requirements established by GCMRC.
Annual evaluations will ensure cooperators are meeting these requirements. GCMRC scientists may
conduct field research and monitoring under the same conditions, particularly in time-sensitive cases
where a formal RFP or other competitive contracting mechanism would not be practicable. In every
case, the USGS will hold its own proposals to the same level of rigorous outside peer review as all
others.
GCMRC will provide appropriate opportunities for agencies with statutory responsibilities to be
involved in the science development and contracting or agreement process.
GCMRC and Reclamation will annually report to AMWG on how much, by percentage, of their
science was contracted through open competitive process and how much was accomplished through
each of the other mechanisms (sole source contract, interagency agreement, performed in-house,
etc.).
GCMRC compliance
There is an open question about whether and/or to what degree GCMRC’s science activities
are having adverse impacts on cultural and natural resources of the Colorado River
ecosystem. This question has raised the expectation that USGS should be involved in
developing and be a signatory to environmental compliance documents covering science
activities. However, USGS policy restricts agency involvement in policy issues (such as
National Environmental Policy Act (NEPA) compliance documents), believing that this
protects the agency’s ability to function as an impartial science provider.
GCMRC will ensure that any negative impacts from AMP-related research activities are monitored,
documented, and addressed in a timely fashion in accordance with applicable federal and state laws.
GCMRC will address NEPA, Endangered Species Act (ESA), and National Historic Protection Act
(NHPA) compliance, and NPS/Tribal research permitting processes, among others, and the resultant
permits can include conditions, restrictions, and mitigation as needed. Such requirements will be
considered by DOI when deciding whether to proceed with the proposed actions.
Protocol Evaluation Panels
Some AMP members believe that fear of causing conflict or ill will is a factor influencing the
quality of feedback from the Protocol Evaluation Panels (PEPs). Therefore, this feedback is
not always as clear and definitive as the AMP desires and needs. AMP members want to
ensure that the charge to each PEP clearly spells out what is desired and expected from the
PEP panel.
As part of the Core Monitoring Evaluation process outlined in the MRP, a TWG information needs
workshop will occur prior to each PEP which will provide more specific guidance from stakeholders on
what needs should be addressed by the PEP.
It is the responsibility of GCMRC to develop the charge to an upcoming PEP. Once the PEP charge
and informational documents have been drafted, they will be sent by GCMRC to the Secretary’s
Designee, the SAs, the TWG Chair, and the Reclamation Program Manager for review and comment
before they are finalized and presented to the PEP Chair. The reviewers will evaluate the documents
for completeness and clarity, and return their comments, if any, to GCMRC within 15 days of receipt.
GCMRC will finalize the documents and distribute them to the Secretary’s Designee, the SAs, the
TWG Chair, and the Reclamation Program Manager.
PEP reports will provide majority or consensus views of the panel members. Where consensus is not
reached, minority views will be documented in the report.
Science performed by other agencies
From time to time, it has been suggested that science support should be obtained through
other science organizations. In addition, some AMP stakeholders perform research,
monitoring, or management activities that could have an impact, positive or negative, on the
AMP and its work, and these activities are not always known to AMWG or the GCMRC.
AMP foundational documents specify that GCMRC is the selected provider and coordinator of
research for the AMP. The EIS defines the authority and responsibility for conduct of research by the
AMP as follows:
All adaptive management research programs would be coordinated through the Center
(Reclamation, 1995, p. 36).
Authorities and responsibilities for GCMRC are also documented in the AMP Strategic Plan:
The Grand Canyon Monitoring and Research Center serves as the science center for the Glen
Canyon Dam Adaptive Management Program (Glen Canyon Dam AMWG, 2002, p. 5).
The Grand Canyon Monitoring and Research Center leads the monitoring and research of the
Colorado River ecosystem and facilitates communication and information exchange between
scientists and members of the Technical Work Group and Adaptive Management Work Group
(Glen Canyon Dam AMWG, 2002. p. 5).
Expanded science and management activities are being implemented by AMP, as well as by its
member agencies, tribes, and other cooperators. Knowledge by all parties of these various activities
is important to effectively manage the AMP.
GCMRC has approved protocols and procedures for responding to AMP science information needs
through its own staff and by contracting with entities external to AMP. If AMWG wishes to advance
certain areas of the program more rapidly, it should identify those priorities to the Secretary’s
Designee. If approved by the Secretary’s Designee, GCMRC will develop a plan to resolve those
concerns in the next 12-month period, perhaps through an accelerated timeline of contracted work
with external entities.
With regard to science or management activities performed by other agencies and not contracted by
GCMRC, it would be to the benefit of the AMP and the other programs if all information about science
and management activities in the CRE were shared. Therefore, land and resource management
agencies and other AMP stakeholders are annually invited and encouraged to notify Reclamation of
all such activities, so they can be included in the BWP. Information about these activities will be
incorporated into the AMP work plan and budget development process.
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