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MFE – POLICY AND TRANSPARENCY TO THE STAKEHOLDERS -U.S. CITIZENS To date MFE teams have attempted to reconcile issues regarding lack of policy and consistent implementation of policies sun-setted in the previous administration’s reorganization and ‘right-sizing’ of Reclamation for the 21st Century, by reissuing old policy. In addition there is a stated goal of MFE to increase the “transparency” of Reclamations policies and decision-making processes to its so-called stakeholders. Most of these policies do not directly affect the lives of Reclamation’s stakeholders or citizens. However, policies set-forth and decisions made by the Dam Safety Office (DSO) can directly impact their lives and rights as citizens. To date, I have not seen any MFE documents addressing policies that have developed over the past 10 years or addressed the ever increasing degree of lack of transparency to citizens and stakeholders in decision-making. A specific example is the development and use of Subjective Risk Assessments in the Dam Safety program. The Dam Safety Office (DSO) has championed and heavily funded the most significant change in the process of dam safety engineering decision-making ever and made it an official policy by setting standards of probability of failure and loss of life required before dam safety modifications are funded. However, the process and standards of the non-scientific subjective risk assessment methodology developed by a small cadre of engineers in the TSC, is not transparent or subject of outside peer review according to policies of OMB and other government agencies that use risk assessment. Initially the method of subjective risk assessment was promulgated by the DSO for the purpose of only ranking the overall priorities for studies of the 300 or so, Reclamation dams. However, as it has been implemented, the DSO requires the TSC, Regions and Area Offices to conduct subjective risk studies to address specific design and engineering questions. The TSC or its contractors provides the ‘leadership’ in the technical implementation of this policy. It even reaches down to the level of whether the expense of drilling an investigation hole in a specific location or number of monitoring instruments will be justified by reducing the risk –or probability of failure of a dam and loss of life. Issues of accuracy and precision of the non-scientific application of subjective probability and the implementation of questionable statistical methods aside are issues of transparency to stakeholders and citizens. It is DSO policy that the supporting data which are used to conduct these risk assessments is cloaked in secrecy from the stakeholders and citizens of the U. S. who live downstream of these dams. The probability standards and levels of risk which warrant a modification or starting an investigation of a potential safety concern are not shared or open to public comment or review. For example, few know that the decision to investigate even just a potential problem or decision to modify a dam is highly dependent upon the estimated loss of life downstream of the dam. All of this information, data and decision-making is classified as “Sensitive” and cannot be released to the public i.e., to the citizens that live downstream of the dams. A dam may exhibit significant problems of seepage or other engineering concern, but if not enough people are predicted to die in the event of a failure, Reclamation will do nothing. It is not a question of loss of project water or economics. It is not a matter of 1 person or 100 citizens downstream that may be killed. It is a probability with an annualized loss of life. In some cases the predicted loss of life may be in the tens or more, and still not be sufficient estimated number of dead to justify taking action, i.e., spending the taxpayer’s money to address the engineering question or issue, even if it is a relatively small amount of funds. Any questions of the legal liability of government when a dam failure occurs (its not if, its when) for unlawful death or engineering negligence of decision-makers and responsible engineers are not addressed in the risk policies of the Dam Safety Office. MFE has the perfect opportunity to address these short-comings in policy and transparency if Reclamation is to better serve the citizens that live downstream of its dams in the 21st Century. Disposition: forwarded to Team 3 "Revise policy development to consider transparency and value added" and Team 7 "Expedite policy for identified gaps."	04/09/2007

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MFE – POLICY AND TRANSPARENCY TO THE STAKEHOLDERS -U.S. CITIZENS

To date MFE teams have attempted to reconcile issues regarding lack of policy and consistent implementation of policies sun-setted in the previous administration’s reorganization and ‘right-sizing’ of Reclamation for the 21st Century, by reissuing old policy. In addition there is a stated goal of MFE to increase the “transparency” of Reclamations policies and decision-making processes to its so-called stakeholders. Most of these policies do not directly affect the lives of Reclamation’s stakeholders or citizens. However, policies set-forth and decisions made by the Dam Safety Office (DSO) can directly impact their lives and rights as citizens.

To date, I have not seen any MFE documents addressing policies that have developed over the past 10 years or addressed the ever increasing degree of lack of transparency to citizens and stakeholders in decision-making. A specific example is the development and use of Subjective Risk Assessments in the Dam Safety program. The Dam Safety Office (DSO) has championed and heavily funded the most significant change in the process of dam safety engineering decision-making ever and made it an official policy by setting standards of probability of failure and loss of life required before dam safety modifications are funded. However, the process and standards of the non-scientific subjective risk assessment methodology developed by a small cadre of engineers in the TSC, is not transparent or subject of outside peer review according to policies of OMB and other government agencies that use risk assessment. Initially the method of subjective risk assessment was promulgated by the DSO for the purpose of only ranking the overall priorities for studies of the 300 or so, Reclamation dams. However, as it has been implemented, the DSO requires the TSC, Regions and Area Offices to conduct subjective risk studies to address specific design and engineering questions. The TSC or its contractors provides the ‘leadership’ in the technical implementation of this policy. It even reaches down to the level of whether the expense of drilling an investigation hole in a specific location or number of monitoring instruments will be justified by reducing the risk –or probability of failure of a dam and loss of life.

Issues of accuracy and precision of the non-scientific application of subjective probability and the implementation of questionable statistical methods aside are issues of transparency to stakeholders and citizens. It is DSO policy that the supporting data which are used to conduct these risk assessments is cloaked in secrecy from the stakeholders and citizens of the U. S. who live downstream of these dams. The probability standards and levels of risk which warrant a modification or starting an investigation of a potential safety concern are not shared or open to public comment or review. For example, few know that the decision to investigate even just a potential problem or decision to modify a dam is highly dependent upon the estimated loss of life downstream of the dam. All of this information, data and decision-making is classified as “Sensitive” and cannot be released to the public i.e., to the citizens that live downstream of the dams. A dam may exhibit significant problems of seepage or other engineering concern, but if not enough people are predicted to die in the event of a failure, Reclamation will do nothing. It is not a question of loss of project water or economics. It is not a matter of 1 person or 100 citizens downstream that may be killed. It is a probability with an annualized loss of life. In some cases the predicted loss of life may be in the tens or more, and still not be sufficient estimated number of dead to justify taking action, i.e., spending the taxpayer’s money to address the engineering question or issue, even if it is a relatively small amount of funds. Any questions of the legal liability of government when a dam failure occurs (its not if, its when) for unlawful death or engineering negligence of decision-makers and responsible engineers are not addressed in the risk policies of the Dam Safety Office. MFE has the perfect opportunity to address these short-comings in policy and transparency if Reclamation is to better serve the citizens that live downstream of its dams in the 21st Century.

Disposition: forwarded to Team 3 "Revise policy development to consider transparency and value added" and Team 7 "Expedite policy for identified gaps."

04/09/2007