October 19, 2011
TO: Members of the Technical Work Group
FROM: Jack Schmidt, Chief, Grand Canyon Monitoring and Research Center
RE: Some thoughts about the Glen Canyon Dam Adaptive Management Program and
GCMRC’s role in that program
----------I have served as Chief for approximately two months, and have had conversations
with some of you about the Glen Canyon Dam Adaptive Management Program
(GCDAMP) and about GCMRC’s role in that program. In conversations with Shane
Capron and Mary Orton, I made a commitment to share with the Technical Work Group
(TWG) some of my preliminary thoughts about the GCDAMP and the GCMRC. My
attempt here is to provide thoughts that might spark a constructive conversation with
TWG members. During the October 20 TWG meeting, there will be an opportunity for
me to listen to your initial reactions. It is my intention to have follow-up conversations
with each of you so that I can learn more concerning your opinions about the GCMRC
and its work.
In 1997, the Secretary of the Interior created the GCDAMP and thereby
established a framework for structured scientific decision making concerning the
Colorado River ecosystem (CRE) between Glen Canyon Dam and Lake Mead reservoir.
The GCDAMP includes five entities, each of whom has a defined role (2008, Report and
recommendations to the Secretary’s Designee from the Roles Ad Hoc Group of the
GCDAMP): the Secretary’s designee, the Adaptive Management Work Group (AMWG),
the Technical Work Group (TWG), the Grand Canyon Monitoring and Research Center
(GCMRC), and independent review panels.
The role of the GCMRC is well defined. The Center is “the provider and
coordinator of research” for the adaptive management program and provides “credible,
independent, and objective” science support concerning the effects of Glen Canyon Dam
and related factors on the CRE. Although changes in the leadership of GCMRC present a
challenge to the continuity of the GCDAMP, these changes also provide an opportunity
to re-evaluate GCMRC’s role in the adaptive management program.

1. The GCDAMP, by definition, is a program of adaptive management. Although
there are other approaches to natural resource management, adaptive
management is the approach being applied in the CRE, by decision of the
Secretary of the Interior in 1997.
An adaptive management program, by definition, involves a program of rigorous
scientific experimentation and analysis, and iterative adjustment of management
decisions as scientific uncertainty is reduced.

Adaptive management places large responsibilities on both scientists and
stakeholders. It is the job of scientists (a) to identify scientific uncertainties, (b) to
develop monitoring programs that quantify the status of key resources, (c) to
develop and characterize variation in the key environmental drivers of the
ecosystem, (d) to develop experimental programs to resolve key uncertainties, (e)
to analyze experimental and monitoring data to inform future management
actions, and (f) to develop models that link potential management actions to
resources consequences. It is the job of the stakeholders (a) to articulate clear,
measurable, and agreed-upon objectives that guide decision making and can be
used to assess progress in achieving management success, and (b) to identify the
suite of potential management actions that are available to be used in the design
of experiments. The literature also points out that adaptive management not only
involve iterative experimentation, scientific analysis, and revision of management
actions, but also iterative reevaluation of program goals, objectives, and range of
potential management actions.
As you all know, adaptive management “is an approach to natural resource
management that emphasizes learning through management, based on the philosophy that
knowledge is incomplete and much of what we think we know is actually wrong” (Allen
et al., 2011, Adaptive management for a turbulent future: Journal of Environmental
Management 92: 1339-1345). Despite the existence of this uncertainty, managers and
policy makers must make decisions, and the process of adaptive management seeks to
decrease uncertainty through a structured process of experimentation. In contrast to
management by trial and error, adaptive management is a formal iterative process with an
explicit decision structure necessitating articulation of goals, management objectives,
hypotheses of causation, data collection procedures, and subsequent evaluation and
analysis, and reiteration (Fig. 1).

Figure 1. A representation of the adaptive management process that highlights the fact that adaptive
management includes a decision component and an opportunity to learn. Structured decision making
(SDM) is not necessarily the equivalent of adaptive management. SDM is simply an organized and
transparent approach to the decision process. What makes adaptive management distinct from structured
decision making is the inclusion of the iterative process of scientific learning that informs revisions of the
decision process (from Allen et al., 2011). Although the GCMRC and the stakeholders participate in many
parts of the cycle of adaptive management depicted in this diagram, GCMRC is primarily involved with
activities on the left side of this circle.

Although the intellectual roots of adaptive management in natural resources
management lie in fisheries management in the 1950s, the term gained wide visibility two
decades later in an edited volume, Adaptive Environmental Assessment and Management
(Hollings, 1978). Carl Walters, a long time advisor to the GCMRC and GCDAMP,
further developed these ideas (Walters, 1986, Adaptive management of renewable
resources), especially in the realm of mathematical modeling.
Adaptive management is considered an appropriate strategy for natural resource
management where there is high scientific uncertainty and there is also a high degree of
controllability of ecosystem drivers (Fig. 2). In the case of the CRE, discharge can be
controlled to a high degree and temperature somewhat less so. In contrast, fine sediment
can be controlled to a lesser extent because it is supplied from unregulated tributaries.
The opportunity for experimentation is primarily provided by the controllability of
discharge. In other managed ecosystems where controllability is high but scientific
uncertainty is low, experimentation is less appropriate, and other management strategies
might be employed, such as pursuit of maximum sustained yield. Other management
techniques are appropriate where ecosystem drivers can only be poorly controlled,
because experiments are more difficult to conduct in such an environment.

Figure 2. Adaptive management is an appropriate strategy where there is a high potential for learning and
the system can be manipulated (adapted from Peterson et al., 2003, Scenario planning: a tool for
conservation in an uncertain world: Conservation Biology 17: 358-366, and reproduced by Allen et al.,
2011).

2. Applying adaptive management to the CRE is a challenge, because the certainty of law
and its administrative application greatly constrains the types of experimentation that
otherwise would be pursued based on adaptive management theory. The GCDAMP, at
present, probably is better characterized as what some call “adaptive management-lite”
– adaptive management constrained by a significant body of law and administrative
rules. Some agencies and stakeholders express frustration about GCMRC proposals for
continued substantive monitoring, research, and experimentation, but this type of work is
essential to the practice of adaptive management. If stakeholders consider the present
uncertainties in understanding ecosystem processes or in predicting the outcome of
management actions to be small, then an alternative approach to adaptive management
could be considered.
There is a significant challenge to meshing adaptive management with the role of
law in the United States’ system of governance. In some cases, the certainty of law and
the inherent rigidity of institutions limits the types of experimentation needed to resolve
scientific uncertainties (Garmestani et al., 2009, Panarchy, adaptive management and
governance: policy options for building resilience. Nebraska Law Review 87: 10361054). Ruhl and Fischman (2010, Adaptive management in the courts. Minnesota Law
Review 95(2): 424-484) have observed that the two-step process of U. S. administrative
law (i.e., a first step that allows public comment on draft documents and the second step
of a final agency action that creates “certainty” to the process and provides the
opportunity for judicial review) is in fundamental conflict with adaptive management,
because the law requires certainty but adaptive management is “based on the realization
of dynamic systems characterized by surprise.” Karkkainen (2005, Panarchy and
adaptive change: around the loop and back again. Minnesota Journal of Law, Science &
Technology 7: 59-77) and Ruhl (2008, Adaptive management for natural resources –
inevitable, impossible, or both? Rocky Mountain Law Institute 54(11): 1-6) have asked if
adaptive management might be impossible under the current framework of administrative
law.
Allen et al. (2011) observed:

In effect, administrative agencies in the USA do not conduct adaptive
management as it was originally conceived (Ruhl and Fischman, 2010). Rather,
agencies conduct “adaptive management-lite”, as the courts have provided
some leeway for adaptive management projects, provided they have
requirements that are legally enforceable (Ruhl and Fischman, 2010). The
primary problem with adaptive management-lite is that it does not measure up
to the standards of adaptive management theory, nor does it hold up under the
scrutiny of substantive and procedural law (Ruhl and Fischman, 2010). Thus if
adaptive management is necessary for good environmental management,
environmental law must be “adapted” to fit with adaptive management (Ruhl,
2008).

In light of the extensive legal and administrative history that has resulted
in the Law of the River, it is not surprising that there is, at times, significant
disagreement and debate about how the GCDAMP ought to function in practice.
Additionally, there is disagreement about how the program operates in relation to
other laws, such as the Endangered Species Act, and to the responsibilities of
land, water, and energy management agencies who are also stakeholders. It is not
surprising that some stakeholders express frustration with the experimental
approach inherent in adaptive management, when they yearn for the certainty of
agency action.
GCMRC should not be blamed for pursuing a systematic approach of
monitoring and measurement, research and experimentation, and data analysis.
Nor should GCMRC be blamed for suggesting new experiments. Resolving
uncertainty is the essence of adaptive management. However, GCMRC needs to
do a better job of framing its scientific work in terms to explicitly describing the
nature of existing scientific uncertainty and how future experiments, monitoring,
or data analysis might reduce that uncertainty. GCMRC should also strive to
articulate the implications of various management actions in relation to that
uncertainty.
In the event that stakeholders declare that the present level of scientific
and management uncertainty is acceptably small, then consideration ought to be
given to abandoning adaptive management as the desired approach to natural
resources management in the CRE. In the meantime, scientific data collection
and reanalysis of scientific paradigms, including proposals for new experiments,
will be the work of GCRMC; it is part of the Center’s job.
3. The fundamental job of GCMRC is to provide “world-class science” input to
the GCDAMP process, while providing planning support to the TWG and
conducting its business in a transparent and economical way. GCMRC is
committed to identify ways to increase its productivity so as to meets these
obligations. Consideration ought to be given to reevaluating the nature of
planning documents developed by GCMRC in support of TWG activities.
Various administrative documents, including the Report of the Roles Ad
Hoc Group, GCMRC’s Strategic Science Plan, and GCMRC’s Monitoring and
Research Plan, discuss the organization and size of GCMRC required to carry out

its functions as a provider and organizer of science. These documents establish an
expectation that GCMRC conduct or supervise science activities that are
consistent with “the world-class quality of USGS science products.” There has
been disagreement, however, about the desired size of the GCMRC staff.
There has also been disagreement about the relative amount of scientific
work conducted by GCMRC staff in relation to work conducted by contractors,
cooperators, other agencies, and universities. Regardless of who conducts this
work, GCMRC is charged with having its scientific activities (proposals, contract
awards, final reports) reviewed by independent peer panels. The sum of these
activities is captured in the Strategic Science Plan’s description of the job of the
GCMRC Chief – to ensure quality science is conducted on priority issues in a
timely manner and in a cost-effective way.
As described in #2, the challenge of the GCDAMP is the challenge of
conducting an adaptive management program in an environment constrained by
laws and administrative policies that limit experimentation, impact some of the
resources under study, and impact the experience of some visitors to the CRE.
The challenge of GCMRC also involves the conflict of how to meet its goal of
conducting and organizing world class science while at the same time providing
sufficient administrative support to assist the AMWG and TWG in conducting its
work. Presently, GCMRC is charged with developing and updating its Strategic
Science Plan, Monitoring and Research Plan, Core Monitoring Plan, Biannual
Work Plan, and to write annual reports, a 5-year summary of the status of CRE
resources (i.e., SCORE report), and a report on the status of knowledge of various
ecosystem processes. Additionally, GCMRC is charged with serving on every ad
hoc committee of the TWG and is expected to actively participate in discussions
and meetings wherever its scientific findings are used in legal or administrative
actions, such as Environmental Assessments and rulings concerning fish or
wildlife.
I am apprehensive that the goals of providing world-class science support
and providing a significant number of planning documents are in conflict.
Although I do not think that GCMRC should abandon its responsibilities to
provide support for the work of the TWG, I do think that GCMRC and the TWG
ought to reconsider the magnitude of planning documents and administrative
reporting that is expected of the organization.
As Chief, I am committed to doing my part to identify ways to restructure
the Center so as to increase productivity of the organization. I have no doubt that
we can structure our organization so as to produce wider visibility for our
scientific activities that in turn yields more critical peer-review about our
program. On the other hand, I do think that it is imperative for the TWG and
GCMRC to continue conversations about the nature of the planning documents
needed by the TWG to meet its responsibilities.
4. The study area that is the focus of GCMRC’s work has consistently been
described as extending from Glen Canyon Dam to Lake Mead, but the primary
focus has been on the mainstem Colorado River. Expanding the geographic scope

of GCMRC research activities would greatly improve the scientific and
management perspective provided to the GCDAMP.
There is a long history of stakeholder discussion about the geographic
scope of GCMRC. There is precedence for studies in Cataract Canyon, located
upstream from Lake Powell reservoir on the mainstem Colorado River, but the
vast majority of GCMRC’s work has focused on the CRE between Glen Canyon
Dam and Lake Mead. Most of that work has been conducted on the mainstem of
the Colorado River. For example, it has been more than a decade since any
ecosystem process level studies have been conducted on humpback chub in the
Little Colorado River. Nevertheless, the key to understanding trends in native fish
populations would well lie in understanding the tributaries better.
Thus, consideration ought to be given to expanding the horizons of
GCMRC research beyond the presently defined CRE. The presently defined
study area limits the perspective of GCMRC scientists in the conduct of their
work. Such an expansion in research perspective would provide GCMRC and the
GCDAMP the opportunity to place the issues of Colorado River science and
management in Grand Canyon in a larger perspective and thereby increase the
quality of science support provided to the GCDAMP.
Such a wider perspective is already held by some of the stakeholders. The
Bureau of Reclamation’s Upper Colorado River region not only includes Glen
Canyon Dam but also includes the rest of the Upper Colorado River basin and the
Rio Grande. The Western Area Power Administration distributes power for
produced by all the power plants of the CRSP. The USFWS is organized into
separate regions that divide the Colorado River basin in two parts. Agency staff
who participate in the GCDAMP inevitably bring with them a larger regional
perspective when they evaluate the management issues of the CRE in Grand
Canyon, yet other stakeholders have more limited geographic perspective. I think
that the GCDAMP and the Secretary’s designee would be better informed if the
GCMRC science program regularly placed issues of Grand Canyon science into a
broader context.
5. Final thoughts …
As Chief of GCMRC, I am searching for ways to achieve the mandate that
GCMRC be a “world class” scientific organization. I do not know how GCMRC
can recognize world-class science unless the Center has staff of the same caliber.
As an agency, it is essential that we must “walk the walk” if we are going to “talk
the talk.”
I do not think that GCMRC must be proficient in every aspect of applied
river science, but I do think that the Center must identify its strengths and the
areas in which it strives to be a national leader. In so doing, we establish a cohort
of staff who can provide advice and interpretation of cutting edge science
activities in a broader range of fields. Thus, my sense is that the GCDAMP
would be best served by a GCMRC staff that included a significant cohort of
national leaders in applied river science and its application to adaptive
management. My challenge is to channel the energy and commitment of my staff,

to expect higher scientific productivity of some and to have other staff members
provide more insightful scientific guidance to the adaptive management process.
The proof of the success of the GCDAMP program is implementation of
new operating plans for Glen Canyon Dam and/or implementation of new on-theriver-and-on-the-ground management actions that improve CRE resources in
desirable ways. The success of the program is not measured by the planning
documents or the science papers that we write. However, the standard of
American science that makes it among the very best in the world today is the
peer-review process of publication in science journals and the written
communication with our science and management peers. My job, as GCMRC
Chief, is to push my staff to conduct its work consistent to the highest standards
of American science. My job is also to provide meaningful science products to the
GCDAMP that ask, “How well do we know that process?” “Is there an alternative
hypothesis?” “Could we be wrong?” Such constant second-guessing is the essence
of adaptive management. Such an effort is also potentially maddening to policy
makers, but that is the course chosen for us by the Secretary of the Interior. In the
end, I think that course will serve us well.