Columbia River Basin Fish and Wildlife Program
Management Review of Contracting Processes
December 1997 | document 98-1
MOSS ADAMS, LLP
1001 SW Fifth Avenue, Suite 1700
Portland, Oregon 97204-1152
Tel (503) 242-1447
Fax (503) 274-2789
Table of Contents
I. Executive Summary
The implementation process for the Columbia River Basin Fish and
Wildlife Program (Program) has undergone significant changes over the past
few years. These changes have responded to the results of a number of
external assessments and internal improvement efforts that have focused on
various components of Program implementation, including planning,
procurement, contract administration, and monitoring and evaluation. Even
as this review was being conducted it was apparent that there were ongoing
efforts to improve the implementation process.
The Northwest Power Planning Council (Council) retained the services of
Moss Adams to initiate a management review of the contracting processes
for implementing the Program. The purpose of the review was to identify
opportunities for improving upon the contracting for Fish and Wildlife
Program implementation projects. This report provides a series of
recommendations that delineates a road map for the Council, Bonneville
Power Administration (BPA), Columbia Basin Fish and Wildlife Authority (CBFWA),
and other Program stakeholders to create greater accountability for the
Program, establish a more cost-effective process for Program development
and implementation, and, ultimately, provide the foundation for a more
successful Program.
It is important to point out that some of the recommendations contained
in this report may not be able to be implemented without careful review of
the constraints placed on various stakeholders by the Northwest Electric
Power Planning and Conservation Act, the Memorandum of Agreement, and
other documents that establish legal requirements for Program
implementation. Proposed changes in roles and responsibilities of existing
entities or the creation of new entities most likely would occur only
through legislative change or mutually agreed upon governance processes.
Recommended changes are summarized below by major process participant.
? Council?Comprehensively update the Program every five
years; when possible, prepare a detailed annual supplement to the Program;
coordinate planning efforts of the various fish and wildlife stakeholders;
prioritize projects as part of the annual planning process; streamline the
proposal review process; develop BPA reporting requirements; develop and
implement a comprehensive project delivery and program performance
monitoring and evaluation framework; and initiate peer reviews.
? BPA?Utilize the solicitation process to request proposals
for implementing priority projects; make modifications to the Bonneville
Purchasing Instructions to strengthen procurement and contract
administration; develop a funding transition policy for maintenance and
operations costs; establish minimum information requirements for
contractor proposals and progress reporting; and evaluate opportunities to
reorganize contract administration personnel to improve the efficiency and
cost-effectiveness of contracting activities.
? CBFWA?Participate in an annual planning and programming
process and work interactively with the Council and BPA to enhance all
facets of the planning and contracting process.
? Independent Scientific Groups?Consider consolidating the
Independent Scientific Advisory Board and Independent Scientific Review
Panel into one group.
Successful implementation of the planning, procurement, contract
administration, and monitoring and evaluation recommendations contained
herein will result in a more comprehensive, cost-effective planning and
implementation process. A suggested comprehensive planning and
implementation process for the Program is depicted in Exhibit 1.
Exhibit 1, Comprehensive Planning and Implementation Process for
the Program
The next step is to assemble representatives of the key stakeholders to
jointly develop a mutually acceptable, detailed action plan for
implementing recommended changes. By working as a team, the Council, BPA,
CBFWA, and independent scientific advisors can achieve this road map for
improving the efficiency and effectiveness of the Program implementation
process. Each of these groups and the public stand to greatly benefit from
the successful implementation of the recommendations contained in this
report.
II. Introduction
The Columbia River Basin Fish and Wildlife Program (Program) is
intended to be a comprehensive plan for protecting and enhancing the
Columbia Basin's fish and wildlife. The process by which the Program is
implemented has changed dramatically over the years.
Changes in how the Program is implemented have resulted from a number
of process assessments that have been conducted since the mid-1980s. These
assessments have ranged from the 1985 Analysis and Development of a
Project Evaluation Process to the 1996 Review of the Columbia River Basin
Fish and Wildlife Program. Assessments have focused on various components
of Program implementation, including planning, procurement, contract
administration, and monitoring and evaluation.
This review concentrates on contract management processes, which
include procurement and contract administration activities in support of
Program implementation. In order to thoroughly evaluate procurement and
contract administration processes, it was necessary to review the
activities that precede and follow these core contracting steps. As a
result, planning and monitoring and evaluation processes were also
assessed to determine the extent to which a solid foundation for and
subsequent follow-through of contract management exist. This effort seeks
to learn from previous relevant assessments and combine past ideas with
those developed as part of the current engagement. The product of this
evaluation is a road map for developing a comprehensive, integrated
approach to contract management for implementing the Columbia River Basin
Fish and Wildlife Program.
A. Background
Three core documents establish the legal framework for the conditions
under which fish and wildlife recovery measures are developed and
implemented in the Columbia River Basin. They include the Northwest
Electric Power Planning and Conservation Act of 1980, the 1996 Memorandum
of Agreement between the four federal agencies vested in the Columbia
River Fish and Wildlife Program, and the 1996 Amendment to the Northwest
Electric Power Planning and Conservation Act of 1980.
1. Northwest Electric Power Planning and Conservation Act
On December 5, 1980, the 96th United States Congress enacted the
Pacific Northwest Electric Power Planning and Conservation Act, herein
referred to as the Northwest Power Act. Stated purposes of the Northwest
Power Act address not only the provision of reliable power to the Pacific
Northwest, but also the safekeeping of the environment in which power is
generated. More specifically, one of the primary purposes of the Northwest
Power Act is:
"to protect, mitigate and enhance the fish and wildlife, including
related spawning grounds and habitat, of the Columbia River and its
tributaries, particularly anadromous fish which are of significant
importance to the social and economic well-being of the Pacific Northwest
and the Nation and which are dependent on suitable environmental
conditions substantially obtainable from the management and operation of
the Federal Columbia River Power System and other power generating
facilities on the Columbia River and its tributaries."
To achieve the purposes of the Northwest Power Act and facilitate
cooperation among the states of Idaho, Montana, Oregon, and Washington,
and with the Bonneville Power Administration, Congress established the
Pacific Northwest Electric Power and Conservation Planning Council, now
known as the Northwest Power Planning Council or the Council. Two core
responsibilities of the Council specified in the Northwest Power Act are
to (1) prepare, adopt, and transmit to the Bonneville Power Administration
a regional power plan and (2) develop and adopt a fish and wildlife
program.
The fish and wildlife program is required to specify measures for
protecting, mitigating, and enhancing fish and wildlife affected by the
development, operation, and management of hydroelectric facilities.
Development of the fish and wildlife program must give consideration to
recommendations provided by the Bonneville Power Administration, federal
fish and wildlife agencies, the region's state fish and wildlife
agencies, appropriate Indian tribes, any entities owning or operating a
hydroelectric facility on the Columbia River or its tributaries, and the
public. Additionally, the 9th Circuit Court's opinion in Northwest
Resource Information Center v. Northwest Power Planning Council (commonly
referred to as the Tang decision) requires the Council to give due
deference to recommendations of the fish agencies and tribes. Funding for
implementing the Council's Fish and Wildlife Program measures is
provided on an annual basis by the Bonneville Power Administration.
The Northwest Power Act calls for the Council to establish a voluntary
scientific and statistical advisory committee to assist in the development
and amendment of a regional power plan. The Council is also permitted to
establish other voluntary advisory committees to assist in carrying out
its functions and responsibilities.
2. Memorandum of Agreement
In September 1996, a Memorandum of Agreement was signed by four federal
agencies concerning the Bonneville Power Administration's financial
commitment for Columbia River Basin fish and wildlife costs. The
Memorandum of Agreement was entered into by the Department of Energy, on
behalf of the Bonneville Power Administration; the Department of the Army,
on behalf of the U.S. Army Corps of Engineers; the Department of the
Interior, on behalf of the Bureau of Reclamation and the Fish and Wildlife
Service; and the Department of Commerce, on behalf of the National Oceanic
and Atmospheric Administration through the National Marine Fisheries
Service. Collectively, these entities are referred to as the Parties.
The Memorandum of Agreement establishes expectations of the Parties for
the Fiscal Years 1996 through 2001 relative to the budget commitment for
fish and wildlife costs covered under the Agreement. Specifically, the
Memorandum of Agreement also sets a multi-year budget for addressing fish
and wildlife obligations along with budget management and program
accountability requirements tied to fish and wildlife expenditures. This
Agreement makes available $127 million per year for capital and operating
expenditures associated with the Council's program. The Agreement
establishes procedures for the development of multi-year and annual work
plans by the Parties, Council, state fish and wildlife agencies, and
Tribes. In addition, it reaffirms the commitment of the Parties to working
cooperatively with the Columbia Basin Indian Tribes.
3. 1996 Amendment to the Northwest Power Act
In 1996, the United States Congress passed a significant amendment to
the Northwest Power Act. The Amendment includes provisions for additional
independent scientific expertise in the evaluation of proposed fish and
wildlife projects, and added responsibilities for the Council. The adopted
changes seek to ensure that fish and wildlife funds are expended in the
most cost-efficient and effective manner possible.
The amendment directs the Northwest Power Planning Council to appoint
an Independent Scientific Review Panel to review projects proposed to be
funded through the Council's fish and wildlife program. The eleven
scientists to comprise the Independent Scientific Review Panel are to be
selected from a list of scientists submitted by the National Academy of
Sciences.
In addition, the amendment calls for the establishment of Scientific
Peer Review Groups to assist the Independent Scientific Review Panel in
making recommendations to the Council for projects to be funded by the
Bonneville Power Administration. Peer Review Group members also will be
selected from a list of scientists submitted by the National Academy of
Sciences.
The 1996 Amendment to the Northwest Power Act requires the Council to
fully consider the recommendations of the ISRP when making its funding
recommendations to BPA. If the Council does not adopt a recommendation of
the ISRP, then the Council must explain in writing its reasons for doing
so. The Council, after consideration of the recommendations of the ISRP
and other appropriate entities, is entrusted with the responsibility of
making the final recommendations of projects to be funded through BPA's
annual fish and wildlife budget.
B. Review Process
The Northwest Power Planning Council retained the services of Moss
Adams LLP to conduct a management review of the contracting process for
implementing the Council's Fish and Wildlife Program. Recognizing the
interrelatedness of contracting (i.e., procurement and contract
administration) with the preceding step of planning and the subsequent
steps of monitoring and evaluation, the review also addressed these
related steps. By evaluating these other processes, we were able to
determine whether the planning phase establishes a solid foundation for
the contracting phase and whether contracting supports the requirements of
monitoring and evaluation.
The review of the Columbia River Basin Fish and Wildlife Program
contracting process consisted of four primary steps. They included project
initiation, fact finding, analysis and assessment, and reporting. Project
initiation focused on gaining an orientation to Program participants and
their roles and responsibilities in the annual contracting process.
Project initiation also involved identifying personnel to be interviewed,
documents to be reviewed, and process components to be evaluated. Fact
finding encompassed an extensive interview and document review process.
Based on the results of fact finding, the contracting process was analyzed
for strengths and opportunities for improvement. Finally, an assessment
was prepared and documented in a final report.
Portions of the contracting process have received significant scrutiny
over the past several years. As a result, a critical aspect of this
assessment entailed reviewing previous relevant assessments and
determining the extent to which recommendations for process improvements
have been implemented. This review seeks to leverage and integrate the
work performed through previous efforts.
The contracting process was evaluated in terms of the
cost-effectiveness of planning and implementation activities. The review
was conducted using standard analysis and assessment techniques. Findings
and recommendations were reviewed with executives from Bonneville Power
Administration, Columbia Basin Fish and Wildlife Authority, and Northwest
Power Planning Council, before being finalized. This report contains all
findings and recommendations, along with a proposed action plan. Although
executives from stakeholder organizations reviewed the findings and
recommendations contained in report, additional distribution, review, and
evaluation by their constituents will be necessary for its final
acceptance.
III. Current Contracting Process
The current contracting process for protecting, mitigating, and
enhancing fish and wildlife in the Columbia River Basin encompasses a wide
range of activities and numerous stakeholders. A holistic view of
contracting and related activities spans from developing and updating the
Columbia River Basin Fish and Wildlife Program, to soliciting and
evaluating project proposals to carry out the Program, to managing project
implementation, and finally to monitoring and evaluating project
effectiveness. Key participants and the current process by which these
activities are accomplished are described below.
A. Key Participants
There are several entities that play critical roles in the development
and implementation of the Columbia River Basin Fish and Wildlife Program.
These organizations include the Northwest Power Planning Council,
Bonneville Power Administration, Columbia Basin Fish and Wildlife
Authority, Independent Scientific Advisory Board, Independent Scientific
Review Panel, and Scientific Peer Review Groups. The general roles and
responsibilities of each of these groups in relation to the Columbia River
Basin Fish and Wildlife Program are briefly described below.
1. Northwest Power Planning Council (Council)
The Council was established by the Northwest Electric Power Planning
and Conservation Act of 1980 to develop a program to protect, mitigate,
and enhance the Columbia Basin's fish and wildlife. The Council is a
planning, policy-making, and reviewing body. It develops and monitors
implementation of the Columbia River Basin Fish and Wildlife Program. It
also is responsible for providing funding recommendations to the
Bonneville Power Administration relative to implementing the Columbia
River Basin Fish and Wildlife Program. The Council works interactively
with the various fish and wildlife stakeholders in carrying out its
duties.
2. Bonneville Power Administration (BPA)
BPA provides funding and implements projects recommended for funding by
the Council. BPA fulfills this responsibility by funding projects,
procuring contracts, and providing contract administration services. Three
separate groups within BPA are involved in this process. They include the
Fish and Wildlife Division, Division of Materials and Procurement, and
Financial Services Group.
3. Columbia Basin Fish and Wildlife Authority (CBFWA)
CBFWA, considered the "managers" of the Columbia Basin
fisheries, represents the interests of a number of entities with a stake
in the Columbia River Basin's fish and wildlife. CBFWA's role in the
planning and programming process includes recommending and prioritizing
fish and wildlife projects within an allocated budget to the Council.
CBFWA members include:
- Federal Agencies?National Marine Fisheries Service and
United States Fish and Wildlife Service.
- State Agencies?Idaho Department of Fish and Game; Montana
Department of Fish, Wildlife, and Parks; Oregon Department of Fish and
Wildlife; and Washington Department of Fish and Wildlife.
- Indian Tribes?Burns-Paiute Indians, Coeur d?Alene Tribe,
Colville Reservation, Kalispel Indians, Kootenai Tribes, Nez Perce
Tribe, Salish-Kootenai Tribes, Shoshone-Bannock Tribes, Shoshone-Paiute
Tribes, Spokane Tribe, Confederated Tribes of the Umatilla Indian
Reservation, Warm Springs Reservation, and Yakama Nation.
4. Independent Scientific Advisory Board (ISAB)
The ISAB was established to provide independent scientific advice and
recommendations on issues related to regional fish and wildlife recovery
programs under the Northwest Power Act and the Endangered Species Act. It
is designed to foster a scientific approach to fish and wildlife recovery
and ensure the use of sound scientific methods in the planning and
implementation of research and recovery strategies related to these
programs. Members of the ISAB are appointed by the chair of the Northwest
Power Planning Council and the regional director of the National Marine
Fisheries Service (NMFS), based on recommendation of senior academic
scientists and the National Research Council. Eleven members serve on the
ISAB. In addition, the Council and NMFS each provide a senior scientist to
serve as ex-officio members.
5. Independent Scientific Review Panel (ISRP)
The ISRP is comprised of eleven independent scientists appointed by the
Council from a list of nominations from the National Academy of Sciences.
The ISRP's role is to review fish and wildlife projects recommended for
funding by BPA. The ISRP is designed to ensure that the projects are
consistent with the Council's Columbia River Basin Fish and Wildlife
Program, based on sound scientific principles, beneficial to fish and
wildlife, and defined by clear objectives and outcomes with provisions for
monitoring and evaluation.
6. Scientific Peer Review Groups
Peer Review Groups are to be established by the Council to assist the
ISRP in making its recommendations to the Council for projects to be
funded through BPA's annual fish and wildlife budget. Peer Review Group
members are appointed by the Council from a list of nominations provided
by the National Academy of Sciences.
B. Current Process and Procedures
The contracting process that supports implementation of the Council's
Columbia River Basin Fish and Wildlife Program consists of two primary
components. They include (1) project prioritization and contractor
selection and (2) contract administration. Two processes highly related to
these contracting activities include (1) planning and (2) monitoring and
evaluation. The relationship of these four processes, the steps embedded
in each process, and the roles of the key process participants are
described below. The current contracting process is illustrated in Exhibit
2.
Exhibit 2, Current Contracting Process
1. Planning
The Pacific Northwest Electric Power Planning and Conservation Act of
1980 requires the adoption of a program by the Council to protect,
mitigate, and enhance fish and wildlife on the Columbia River and its
tributaries affected by hydroelectric projects. The Council developed the
first Columbia River Basin Fish and Wildlife Program in 1982. The Program
is required to be reviewed at least once every five years. The Program was
amended in 1984, 1987, 1991-1993, and 1994. The 1994 Program represents
the current long-range plan for the Columbia River Basin. Since the 1994
Program only dealt with anadromous fish, amendments to the 1994 Program
were issued by the Council on September 13, 1995, to address resident fish
and wildlife measures.
The Program is developed and amended by the Council by requesting
recommendations from the region's federal and state fish and wildlife
agencies, Indian tribes, and other interested parties. The Program
establishes measures to protect, mitigate, and enhance fish and wildlife
affected by hydroelectric dams; objectives to develop and operate
hydroelectric dams in a manner that protects, mitigates, and enhances fish
and wildlife; and a coordinated approach to fish and wildlife management,
research, and development. Ultimately, the Program provides the foundation
and framework for annual fish and wildlife projects proposed for BPA
funding.
2. Prioritization and Selection
Six to nine months before the beginning of a fiscal year, the project
prioritization and contractor selection process is initiated for the
upcoming federal fiscal year (i.e., October 1st through September 30th).
BPA and the Council solicit project proposal applications from fish and
wildlife agencies, tribes, universities, local governments, and others to
address the measures and objectives contained in the Program. The
application process is open to the public, but the solicitation is not
advertised. The application, known as the "BPA Form," is a
multi-page document that applicants must use to provide details of
proposed projects. Key steps for the remainder of the prioritization and
selection process are provided below.
BPA (Fish & Wildlife Division) accumulates the completed
applications and forwards them to CBFWA and the ISRP. CBFWA reviews and
prioritizes the projects. In order to prioritize proposed projects, CBFWA
uses evaluation criteria it developed and the Council approved. The
product of CBFWA's efforts is the Annual Implementation Work Plan (AIWP),
which contains CBFWA's funding recommendations. The AIWP must meet the
following allocation of project dollars: 70% to anadromous (migrating)
fish, 15% to resident fish, and 15% to wildlife (recommended by the
Council).The AIWP is submitted to the Council.
As a result of the 1996 Amendment to the Northwest Power Act, the ISRP
was created to ensure proposed projects are evaluated based on their
scientific merits and consistency with the Fish and Wildlife Program. The
ISRP also reviews the proposals and provides recommendations for project
funding to the Council.
The timing of the 1996 Amendment to the Northwest Power Act did not
permit the ISRP to be formed in time to review for FY98 the several
hundred project applications in the depth desired. The ISRP intends to
play a more significant role in evaluating the scientific foundation for
projects proposed to be funded in FY99.
The Council receives and reviews the recommendations of CBFWA and the
ISRP for consistency with the measures and objectives of the Program. In
addition, the Council reviews recommended projects relative to cost
effectiveness, ocean impacts, and public comment as required by the 1996
Amendment to the Northwest Power Act. Public comments are accepted on the
recommendations for at least 30 days. The fish and wildlife managers then
have an opportunity to review the comments and make changes to their
recommendations.
The Council submits its funding recommendations to the BPA. The Council's
recommendations may differ from that of CBFWA or the ISRP, however, any
variations from the ISRP's recommendations must be accompanied by a
written explanation by the Council. BPA is charged with defining the scope
of projects, selecting project contractors, and negotiating budgets and
contract terms for Council recommended projects. BPA is not bound by the
Council's recommendations but in recent years has closely followed them.
The process by which Council recommendations, which often include
conditions, are translated into detailed work plans represents one of the
primary and most time consuming duties of BPA's Fish and Wildlife
Division. This function is performed by Contracting Officer's Technical
Representatives. They work with prospective contractors to develop
scientifically sound work plans that constitute detailed recommendations.
Work plans include a detailed scope of work, schedule, and cost estimate.
Ultimately, BPA selects contractors to implement the work plans and
negotiates project budgets and contract terms. These contracts are
typically entered into with the same contractors that submitted project
proposals.
3. Contract Administration
Contract administration spans from the time of contract award to final
receipt and acceptance of the contracted services. BPA has full
responsibility for contract administration. There are three groups within
BPA that play integral roles in contract administration. They include the
Fish and Wildlife Division, Division of Materials and Procurement, and
Financial Services Group. The representatives of these divisions that are
involved in contract administration include the Contracting Officer and
Contracting Officer's Representative from the Division of Materials and
Procurement, Contracting Officer's Technical Representative from the
Fish and Wildlife Division, and personnel from Disbursement Operations
within the Financial Services Group.
The Contracting Officer (CO) is responsible for ensuring performance of
all actions required for effective contracting, ensuring compliance with
contract terms, and safeguarding the interests of BPA in its contractual
relationships. Contracting Officers often designate a contract specialist,
referred to as a Contracting Officer's Representative (COR), to perform
contract preparation and administrative work. In addition, a Contracting
Officer's Technical Representative (COTR) is designated and authorized
by the CO to perform technical contract administration activities on
behalf of the CO, within limits specified by the CO.
The CO, COR, and COTR work as a team to administer a contract. Each
member of the team is responsible for portions of the contract
administration process. The CO, with the assistance of the COR, performs
the following duties:
- Monitors the financial and administrative aspects of the contract
through the COTR;
- Maintains the official award files;
- Handles correspondence and reports (other than technical) relating
to the terms and conditions of the contract;
- Maintains copies of all relevant correspondence between the COTR and
contractor;
- Reviews property acquisition and management and arranges for
disposition of property after completion or termination of the
project;
- Orders changes and modifications to the contract; and
- Closes the contract.
Once a project is awarded, it is the COTR's responsibility to work
with the contractor to develop a final scope of work, budget, and
schedule. Following this project initiation phase, the COTR monitors the
contract to ensure BPA receives, in a timely manner, the goods or services
that conform to the technical requirements of the contract. Specifically,
the COTR performs the following duties:
- Serves as a liaison between the contractor and CO on contractual
matters;
- Maintains a record of all communications with the contractor and
significant events relating to the contract;
- Assists the contractor in interpreting technical requirements of the
contract;
- Recommends to the CO changes to the scope, budget, and/or schedule
for the work with appropriate technical and cost justification;
- Monitors contractor performance;
- Reviews and recommends payment of invoices;
- Provides acceptance of final deliverables; and
- Performs technical analyses of contract cost proposals for contract
modifications or extensions.
The Finance Division's involvement in contract administration is
limited to recording actual payments and draws and processing the checks
to contractors. Contractors can receive payment in one of two ways. The
first payment method is a request for reimbursement, whereby a contractor
submits a Request for Advance/Reimbursement Form and invoice in order to
receive payment for services rendered. COTR approval of the request is
required for Disbursement Operations to process a check.
A second method of payment, which applies only to intergovernmental
contracts, is an on-line payment. In this case, payments are disbursed
using the U.S. Treasury's On-Line Payment and Collection (OPAC) system.
Payments are transferred from BPA's account with the U.S. Treasury to
the contractor's account. Disbursement Operations sends a hard-copy
billing of the transaction to the COTR for review and approval. Even
though this step takes place after funds have been disbursed, BPA can make
adjustments to the account of the contracting agency, if necessary.
Contractor advances, through a letter of credit, are no longer permitted,
as of FY97.
4. Monitoring and Evaluation
Monitoring and evaluation are supported by contractor progress
reporting. Each year, progress reports prepared by contractors are
intended to provide the information needed to determine whether a project
is achieving its objectives. The Memorandum of Agreement also establishes
requirements for project progress reporting, program performance
monitoring, and other accountability measures by the Parties participating
in the Memorandum of Agreement.
The monitoring and evaluation process was recently strengthened by the
1996 Amendment to the Northwest Power Act, which introduced the ISRP and
Peer Review Groups to the project evaluation process. The Amendment calls
upon the ISRP to annually review contractor progress reports as part of
the project evaluation process. In addition, a peer review will be
conducted of continuing projects. The ISRP recommended peer reviews be
conducted every three to five years. They can also be conducted more
frequently. Ongoing efforts to strengthen monitoring and evaluation
include the Council's development of an Integrated Framework for Fish
and Wildlife Management in the Columbia River Basin and BPA's
development of a Standard Template for Projects.
IV. Contracting Opportunities for Improvement
A. Procurement
Procurement represents one of two core components of a contracting
process. The current contracting process for Program implementation is
more accurately defined as project prioritization and contractor
selection, as identified in Section III, Current Contracting Process.
Procurement findings and recommendations address opportunities for
improving the process by which project services are solicited and
retained. Procurement should span from proposal solicitation to contract
negotiation and award. A thorough procurement process will support
cost-effective contract administration.
It is important to acknowledge that there are unique institutional and
legal requirements that place certain limitations on the degree of
cost-effectiveness that can be achieved in BPA's procurement process.
This review recognizes these barriers but, nonetheless, attempts to
identify findings and recommendations that would otherwise achieve a
higher level of cost-effectiveness. Institutional and legal requirements
may be addressed as opportunities arise in the long term.
1. Finding: Proposal solicitation initiates the project
prioritization and contractor selection process instead of the procurement
process. The BPA Proposal Form is used to solicit project proposals. BPA
works with contractors submitting proposals to develop detailed work plans
for priority projects. These work plans provide the basis for subsequent
contract negotiations. In some cases, scopes of work, schedules, and cost
estimates have significantly changed from the proposal stage to the
contract negotiation stage.
Recommendation: Utilize the solicitation process to request
proposals for implementing projects that have been defined in a detailed
manner and prioritized during the annual planning process. (See planning
findings #2 and #4.) Once proposals have been reviewed and evaluated,
contract negotiations can be initiated with the highest ranked, qualified
bidder.
If a project scope of work, schedule, and cost estimate are prepared
during the planning phase, then a more detailed project definition will be
able to be provided to prospective bidders. This will enable bidders to be
more definitive in their proposed work plans, schedules, and budgets. This
will help to reduce discrepancies between proposed and negotiated work
plans, schedules, and most importantly budgets.
2. Finding: There are many organizations involved in the annual
project proposal review process, which results in an inefficient process
and difficulty in pinpointing accountability for Program implementation.
Currently, BPA solicits and receives proposals and then forwards them to
CBFWA and the ISRP. CBFWA reviews the proposals and packages them into an
Annual Implementation Work Plan (AIWP). The AIWP, which contains CBFWA's
funding recommendations, is submitted to the Council. The ISRP reviews the
proposals and also provides recommendations to the Council. The Council
reviews CBFWA's and ISRP's recommendations, and then provides its own
funding recommendations to BPA. It is recognized that some streamlining
occurs through an informal collateral review of the proposals, while CBFWA
is preparing the AIWP.
Recommendation: Streamline the proposal review process by
placing the sole responsibility for review with a single entity. This
existing or new entity may require some scientific support from
independent scientific advisors to evaluate the scientific principles upon
which a particular approach to a project is based. However, the need for
an extensive scientific evaluation of proposals, with the exception of
peer reviews, should be replaced by incorporating scientific input from
independent scientific advisors in the planning process. (See planning
findings #2 and #5.)
It is important to point out that a legal review will be needed to
assess the implications of the suggested changes related to the 1996
Amendment to the Northwest Power Act and Memorandum of Agreement, and to
ensure consistency with the Tang decision. In all likelihood, legislative
changes would be required to establish a new entity and/or realignment of
roles and responsibilities for the entities currently involved.
3. Finding: There is a lack of competition in the procurement
process. When a project involves an entity that has the responsibility to
manage the property or resource to be affected by the services to be
performed, BPA exercises its ability to conduct noncompetitive
transactions under Bonneville Purchasing Instructions (BPI) 11.7.1.2.
Practically, BPA cannot expect to receive competing proposals when this
clause applies. Unless permission is granted to another organization, only
the entity with responsibility for managing the targeted property is
likely to have authority to perform work on the property.
However, many of the contracts with public entities encompass sizable
subcontracts with other public entities and private firms. BPA should not
be limited in its ability to receive proposals that contain competitively
bid subcontractor services.
Recommendation: Assess the feasibility of modifying the
Bonneville Purchasing Instructions to acquire subcontractor services by
competitive procurement. At a minimum, this should require receipt of
three proposals for services or, if three proposals were not able to be
obtained, evidence that bids were solicited from at least three firms. All
other contracts should be competitively bid in accordance with
requirements established in the BPI. Legal issues will need to be reviewed
in this regard. Alternatively, there may be other methods derived (i.e.,
benchmark projects, studies, etc.) that would allow BPA to assess the
relative cost competitiveness of contracts.
4. Finding: Some "pass through" contracts include an
agency administrative fee. Pass through contracts are contracts that have
been executed with an entity having responsibility to manage the property
or resource to be affected by the services to be performed even though all
or most of the services rendered are provided by another organization
through a subcontract.
Recommendation: Consider revising the Bonneville Purchasing
Instructions to either 1) define criteria for use in determining the
permissibility of "pass through" fees or 2) develop a standard
methodology for calculating administrative fees. In order for
administrative fees to be justified, value must be added to the
administration process or additional administrative costs must be avoided.
5. Finding: A large percentage of the BPA funds available for
implementation of the Program are now being spent on maintenance and
operations costs associated with ongoing projects/facilities. This
increasingly limits the ability to fund new projects and tends to minimize
opportunities to apply adaptive management principles.
Recommendation: Develop a framework for transitioning from BPA
to fishery managers or other sources of funding for maintenance and
operations costs. A phased process of gradually decreasing BPA funding for
maintenance and operations of operational projects should be considered.
If possible, estimated maintenance and operations costs should be
developed at the project proposal stage rather than at the operational
stage. An alternative would be to determine a basis for allocating funding
not only for anadromous and residential fish, but also for research,
development, and maintenance and operations costs. Incorporate any funding
policy changes into the proposal solicitation process. It is recognized
that implementation of these recommended changes would likely require
modifications to the Memorandum of Agreement.
B. Contract Administration
Contract administration represents the other core component of a
contracting process. Contract administration findings and recommendations
concentrate on cost-effective enhancements of procedures for initiating,
monitoring, modifying, and renewing contracts. Contract administration
involves development of project work plans, budgets, and schedules;
documentation and justification of modifications; invoice review and
approval; and progress reporting. Many of the findings and recommendations
resulted from the review of representative contract files.
1. Finding: There are many BPA personnel involved in the
administration of contracts, which can result in lack of consistent focus
and miscommunication. A typical contract is assigned a CO, COR, and COTR.
None of these personnel appear to have all of the information they need to
properly fulfill their responsibilities. The COTRs are reported to be
understaffed.
Recommendation: Evaluate the feasibility of integrating the COR
fish and wildlife contracting and COTR functions within the BPA Fish and
Wildlife Division. Integration of these functions will provide the
opportunity to enhance the cost-effectiveness of contract administration
processes through improved communication, common supervision, streamlined
processes, and more efficient resource utilization. Implementation of this
recommendation will require further organizational analysis.
2. Finding: There appear to be lower standards applied to public
contractors than their private sector counterparts regarding information
requirements for work plans. Typically, public entities appear to have
been allowed to provide less detailed work plans than their private sector
counterparts. This has been particularly true for cost estimates. Private
entities have been required to tie cost estimates to specific tasks, while
the requirements for public contractors have been less restrictive.
Recommendation: Apply the same high standards for information
requirements to both public and private contractors relative to the
preparation of work plans. These standards should include identification
of labor costs, expenses, and timing of activities by task. In addition,
performance results for the project should be clearly documented, based on
the detailed work plans. Specifications currently being developed by BPA
for contractor project management plans should be incorporated into
contractor work plan requirements.
3. Finding: Contract agreements between BPA and contractors for
multi-year projects do not specify multi-year cost estimates and often do
not provide multi-year work plans. In some cases, multi-year cost
estimates are included in project proposals. Cost estimates beyond the
first year of a project are critical to the Council being able to make
informed decisions regarding multi-year budget implications of proposed
projects.
Recommendation: Require contract documents for multi-year
contracts to include multi-year work plans and cost estimates. Again, cost
estimates should be provided by task and updated annually. This could also
help address the problem of projecting ongoing maintenance and operations
costs once a project is complete. (See procurement finding #5.)
4. Finding: There is a lack of correlation between project time
frames and project budgets. Multi-year contracts specify the duration of
the project, yet the "not to exceed" budget reflects the current
year budget plus any previous year budgets. Future costs are not reflected
in the "not to exceed" budget.
Recommendation: Indicate both the total and annual "not to
exceed" budgets for the entire project in contract agreements. This
will provide the capability to track actual versus planned expenditures on
annual and total project duration bases.
5. Finding: It appears that contractor work plans are often
developed to justify a cost estimate equal to the BPA budget allocated to
the project. It was reported that BPA budget allocations are viewed by
contractors as guaranteed funding. As a result, statements of work and the
associated cost estimates appear to be driven more by the allocated budget
than the level of effort required to accomplish the objectives of the
project.
Recommendation: Require COTRs to apply greater scrutiny to
contractor work plans and cost estimates. COTRs would be aided by the
availability of more detailed project descriptions, cost estimates, and
schedules being incorporated by the Council into the annual Program
supplement (planning finding #2). Contract cost-effectiveness could also
be improved through enhanced opportunities for competition as described in
procurement finding #3.
6. Finding: There is little written explanation provided by COTR's
when recommending modifications to existing contracts. COTRs prepare a
memorandum to recommend contract modifications to the CO. These memoranda
rarely provide support for modifications based on contractor performance
or other project status information. Furthermore, these memoranda
frequently do not specify the amount of the recommended modification or
the modification number. Similarly, purchase requisitions for
modifications do not specify the modification number.
Recommendation: Require COTR memoranda recommending contract
modifications to provide justification for and details of the
modification. Require related documents to include key identifying
information to tie them together. For instance, modification purchase
requisitions, modifications, and COTR modification memoranda should all
identify the modification number, amount, and time period. This will
provide a better basis for COs and others to review and approve contract
modifications. This recommendation also relates to contract administration
finding #11.
7. Finding: Contracts sometimes change considerably in scope and
budget, and create the appearance of avoiding the annual proposal review
and prioritization process. When significant changes occur, it is often
difficult to correlate original and revised specifications of a project.
Recommendation: Develop criteria for re-authorizing projects
once they exceed a threshold for a specified budget, schedule, or scope of
work modifications. It would be appropriate to establish different
requirements for different types of projects and conditions. For example,
research, construction, and monitoring and evaluation projects would
likely warrant different requirements.
8. Finding: When master agreements are utilized, individual and
aggregate project costs are not always tracked. Master agreements are
established when multiple related projects are anticipated to implement a
measure.
Recommendation: Track both individual and aggregate project
costs covered by a master agreement. This will assure that decision makers
not only know how much money is being expended in aggregate under a master
agreement, but also the level of expenditure on each project covered by
the master agreement.
9. Finding: COTR Status Reports provide little information
relative to the performance of the contractor and status of the project.
These status reports are provided with invoices and contractor progress
reports to the CO/COR. COTR Status Reports are used more as a transmittal
document than a source of insightful information, since they normally
provide no written comments. Routine status reports are required by the
BPI (Appendix 14A.3.1), but apparently are not prepared.
Recommendation: Ensure that COTRs fulfill the requirement to
prepare monthly or quarterly status reports that provide detailed
information regarding schedule status, budget status, accomplishment
status for the reporting period, expected activities for the upcoming
reporting period, and any issues that need attention. Modify the COTR
Status Report as necessary to accommodate this information. COTR Status
Reports should provide an opportunity to keep both the CO/COR and Council
informed of project status.
10. Finding: In some cases, BPA has experienced difficulty
obtaining contractor progress reports and supporting documentation for
invoices. Some entities have been inconsistent in providing a detailed
breakdown of expenditures covered by an invoice. It appears that it is the
norm for annual and quarterly contractor progress reports to be submitted
late or not at all. A process has not been established to enforce
contractor reporting requirements.
Recommendation: Ensure CO/COR/COTRs receive the support
necessary to enforce contractor reporting requirements. Do not approve
invoices unless they provide sufficient detail and are accompanied by a
progress report. BPA cannot be expected to properly manage contracts if
they cannot obtain the information needed to assess project status and the
accuracy of invoices. Repeated absence of contractor status report could
be one of the criteria which prompts a project re-authorizing review. This
recommendation is consistent with the accountability requirements set
forth in the Memorandum of Agreement for the Parties to provide
information, data, and evaluations for projects.
11. Finding: CO/COR prepared Cost Analysis forms are not
accompanied by supporting documentation. These forms cover verifications
related to direct labor pay schedules, fringe rates, travel costs, vehicle
rental rates, equipment and supplies prices, operations and maintenance
costs, and subcontracting costs. CO/COR and COTR files contained no
documentation for the analyses conducted to support stated verifications,
including obtaining fair market prices for equipment and supplies and
fairness and reasonableness of subcontractor estimates.
Recommendation: Ensure documentation supporting cost analysis
pertaining to contract agreements and modifications is present in contract
files. This information is central to helping ensure competitive costs are
realized.
12. Finding: Contractor invoices are not itemized by task and
generally not correlated to progress. Invoices itemize labor costs and
expenses, but they are not tied to tasks. Costs that are itemized by task
provide another means of measuring progress and tracking budget status.
Recommendation: Require contractor invoices to itemize labor
costs and expenses by task. This recommendation relates to contract
administration recommendation #3, which requires cost estimates in work
plans to be itemized by task.
13. Finding: Contractual agreements that provide a letter of
credit for the contractor have significantly complicated BPA's ability
to manage project budgets. Prior to 1997, letters of credit were permitted
for contracts with fish and wildlife agencies and resulted in
disbursements being made faster than anticipated and, in some cases,
exceeding project budgets. For example, a review of contract files
revealed a double payment in the amount of $112,866.11. The double payment
occurred due to one payment being made via a draw through the letter of
credit process, and a second payment mistakenly being made when the
invoice documenting the draw was received. In addition, it was reported
that invoices submitted to substantiate draws have tended to be received
by BPA long after draws were made and sometimes did not match the amount
of the draw.
Recommendation: Do not reinstate letter of credit contracts, and
resolve the identified double payment.
14. Finding: Contractual agreements with other federal agencies
that provide for on-line disbursements have also hindered BPA's ability
to manage project budgets. As specified in Bonneville Purchasing
Instructions 14A.8.3, contractor payments for intergovernmental contracts
with other federal agencies permit disbursements using the U.S. Treasury's
On-Line Payment and Collection (OPAC) system. Under this system, payments
are initiated by the contractor, and funds are generally transferred to
the contractor before BPA can review and approve the associated invoice.
However, BPA has an opportunity to review and, if necessary, correct the
billing by generating a credit or charge back entry to the account of the
contracting agency. The amount drawn sometimes differs from the amount
shown on the invoice. No evidence was found of transactions being reviewed
by the COTR. This lack of review creates the potential for payments to be
made in excess of established contract ceilings.
Recommendation: Modify the BPI to require contractors to submit
and obtain BPA approval of invoices before draws are made through the OPAC
system for the amount shown on the invoice.
15. Finding: The Council does not receive information sufficient
to keep adequately abreast of project status. Information exchange
deficiencies between BPA and the Council exist relative to contract
modifications, including scope, schedule, and budget. The Council also
receives limited information on project results, especially regarding
monitoring and evaluation assessments. There is a quarterly project review
process with BPA and the Council that is intended to address project
status, however, the information provided appears to primarily deal with
budget status. This lack of information makes it extremely difficult for
the Council to follow project progress and evaluate the cost-effectiveness
of projects.
Recommendation: Develop BPA reporting requirements to the
Council. This will require BPA and the Council to work together to
determine (1) the Council's general and project specific information
requirements and (2) how BPA can respond to the identified information
needs. Process details will include the timing, format, and content of
information provided by BPA to the Council.
A key to success is establishing project checkpoints for Council
review. Project checkpoints should begin with contract negotiations and
conclude with project close-out. In addition, the Council should be
informed of any proposed changes to project scope, cost, or schedule that
exceed predetermined thresholds established jointly by BPA and the
Council.
V. Other Opportunities for Improvement
During the course of the review it became clear that potential changes
to other Fish and Wildlife Program activities also provide an opportunity
to improve the cost-effectiveness of procurement and contract
administration. Opportunities for additional improvement have been
identified in the planning and monitoring and evaluation phases of Program
development and implementation.
Several of the recommendations contained in this section would likely
require changes in the roles and responsibilities of entities involved in
the planning and implementation of the Fish and Wildlife Program. It is
recognized that changes in planning and implementation roles and
responsibilities may not be permitted by the current constraints of the
Northwest Power Act, Gorton Amendment, Memorandum of Agreement, various
court settlements and rulings as well as authorities vested with federal,
state, and Tribal entities involved. However, it is also understood that
legislation stemming from electric industry deregulation, expiration of
the Memorandum of Agreement, and processes which may emanate from the
Three Sovereigns discussions could provide opportunity for consideration
of more efficient and cost-effective means for Program implementation.
A. Planning
Planning precedes program implementation and therefore should provide a
comprehensive foundation for projects upon which procurement and contract
administration is built. Comprehensive planning should encompass
establishing policy direction, identifying and prioritizing needs,
defining corresponding projects that are grounded in science, making
budget allocations, and specifying performance expectations. Comprehensive
planning that incorporates stakeholder participation and scientific review
is critical to cost-effective contracting.
1. Finding: The Columbia River Basin Fish and Wildlife Program
is required by law to be reviewed at least once every five years. The
Program was amended in 1984, 1987, 1991-1993, and 1994. The 1994 Program
represents the current long-range fish and wildlife plan for the Columbia
River Basin. The Program was most recently amended in 1995. Plan amendment
processes require a substantial effort by the Council and the region's
stakeholders. The process can easily require 9 to 12 months.
Recommendation: Comprehensively update the Program every five
years. The Program should cover a five-year time frame, and it should be
updated based on the results of monitoring and evaluation. The five-year
update should focus on the framework, goals, and objectives. The primary
product of the Program should be strategies for protecting, mitigating,
and enhancing fish and wildlife.
2. Finding: The Columbia River Basin Fish and Wildlife Program
does not contain all of the information typically contained in a
comprehensive plan. The primary components of a comprehensive plan include
goals, objectives, needs/solutions, cost estimates, and implementation
schedules. The Program provides a broad framework, goals, and objectives.
The lack of detail of the Program has likely contributed to the finding of
the ISRP that there is a noticeable difference between the mix of projects
actually funded and the ISRP's interpretation of the intent of the Fish
and Wildlife Program.
Recommendation: Initiate an annual planning process to develop
fiscal year details that supplement the Program by providing specific
direction for addressing fish and wildlife needs in the Columbia River
Basin. This annual planning process would be a collaborative effort of all
the stakeholders, including BPA, CBFWA, the Council, independent
scientists, and others, and would provide comprehensive guidance for the
entity ultimately responsible for preparing the plan. The primary product
of the annual supplement would be tactics for protecting, mitigating, and
enhancing fish and wildlife. Together, the Program and annual supplement
would serve as a comprehensive plan.
A suggested process for annually preparing a supplement to the Program
is illustrated in Exhibit 3. Ongoing monitoring and evaluation of existing
projects during the course of the year will provide critical input to the
annual planning process.
Exhibit 3, Suggested Planning Process
3. Finding: Multiple "planning" documents exist that
are highly interrelated but not fully integrated. Existing plans include
the Council's Columbia River Basin Fish and Wildlife Program, the
fisheries manager's Multi-Year Work Plan and Annual Implementation Work
Plan, and the Tribal Restoration Plan (Wy-Kan-Ush-Mi Wa-Kish-Wit). Other
related documents include "Return to the River," which was
prepared by the Independent Scientific Group, "Upstream," which
was developed by a National Research Council panel, and the relevant
biological opinions of the National Marine Fisheries Service (NMFS) and
United States Fish and Wildlife Service. These documents and the visions
and solutions they set forth need to be integrated to the greatest extent
possible.
Recommendation: Coordinate the planning efforts of the various
fish and wildlife stakeholders to develop one regional plan, the Columbia
River Basin Fish and Wildlife Program. As recommended by the ISRP, this
plan should reflect the "Integrated Framework for Fish and Wildlife
Management in the Columbia Basin" developed by the Council. The
Program must attempt to encompass the Endangered Species Act requirements.
The Tribal Restoration Plan should be factored into the Program through
strengthened participation of the region's Indian tribes in both the
five-year and annual planning processes. By consolidating planning
activity on the development of a single, comprehensive plan (i.e.,
five-year Program and annual supplement), the region's stakeholders will
have clearer direction for achieving the fish and wildlife goals.
4. Finding: Projects are currently intended to be prioritized as
part of the proposal evaluation process in response to proposals, instead
of during the annual planning process. In addition, the Program appears to
provide little guidance regarding the relative priority of measures.
Attempting to identify and address the priority needs of the region
through a procurement and budget allocation process for project proposals
is at best a difficult and complex approach and not conducive to
cost-effective contract implementation. For example, the Fiscal Year 1997
project proposal solicitation process resulted in the submittal of 400
project proposals that may or may not have been entirely responsive to the
priority needs of the region. Of these, 224 projects were recommended for
funding using prioritization criteria develop by CBFWA and approved by the
Council.
Recommendation: Prioritize projects as part of the planning
process. Scope projects in response to identified needs, evaluate projects
against the available budget, and finally prioritize projects to provide
the basis for the annual BPA solicitation for proposals. The product of
this prioritization process should be a list of priority projects
identified in the annual Program supplement that are achievable within the
annual BPA budget available for fish and wildlife activities related to
the Program. This is not unlike the concept that is currently being
applied to watershed restoration and research, whereby needed projects are
identified and prioritized and then proposals are solicited in response to
priority projects.
5. Finding: Consistency between Program development and
implementation is hindered by the participation of multiple independent
scientific groups. Both the ISAB and ISRP contribute scientific expertise
to the process. The ISAB provides independent scientific advice to the
Council and NFMS, while the ISRP reviews fish and wildlife projects
recommended by CBFWA for funding by BPA.
Recommendation: Consider consolidating the ISAB and ISRP into
one independent scientific group to support development and implementation
of the Program, based on the costs and benefits of consolidation. This
consolidation should not require substantial membership change, since
eight of the eleven members of the ISRP are also members of the ISAB. The
roles of the consolidated group should be to support development of the
Program and annual planning supplement and assist in the evaluation of
project results. This consolidation would minimize the funding
complexities associated with compensating the members of two scientific
panels whose work may involve overlapping tasks.
B. Monitoring and Evaluation
Monitoring and evaluation can be useful in assessing the results of
procurement and contract administration. Monitoring and evaluation
findings and recommendations identify opportunities to strengthen future
decisions based on past performance results. This area has received
extensive attention over the past several years, because it represents one
of the greatest opportunities to improve the efficiency and
cost-effectiveness of Program implementation.
1. Finding: Current monitoring and evaluation activities are
generally insufficient to support cost-effectiveness decisions. The need
for more effective tracking and evaluation of project performance is well
recognized. This topic was a focus of multiple reviews commissioned by the
Council. These efforts range from the 1985 "Analysis and Development
of a Project Evaluation Process," prepared by Charles C. Coutant and
Glenn F. Cada, to the 1996 ISRP review of the Columbia River Basin Fish
and Wildlife Program.
In addition, the BPA Fish and Wildlife Division recently developed a
Standard Template for Projects (STP), dated June 26, 1997, to facilitate
fair and effective project tracking. The STP is intended to 1) attain and
maintain a high level of technical quality in implementation of the Fish
and Wildlife Program and 2) ensure that projects selected for funding
demonstrate that BPA funds are being used wisely and efficiently toward
meeting the goals and objectives of the Program.
Recommendation: Develop a comprehensive framework for project
delivery and program performance monitoring and evaluation that supports
decisions based on cost-effectiveness as well as scientific merit. Project
delivery monitoring and evaluation would compare what was actually
implemented with what was planned to be implemented to determine how well
projects were accomplished. Program performance monitoring and evaluation
would compare the actual impact of implemented projects with the stated
objectives of the projects. Both components are essential to address the
cost-effectiveness of fish and wildlife strategies and tactics.
In addition, it will be necessary to identify data requirements to
support project delivery and program performance monitoring and
evaluation. This should include identification of what information is
needed from which organizations and how the information will be reported
and utilized. Revisit the STP to assess its ability to meet these
information needs. A suggested program and performance monitoring and
evaluation process for the Fish and Wildlife Program is illustrated in
Exhibit 4.
Exhibit 4, Suggested Project Delivery and Program Performance
Monitoring and Evaluation Process
2. Finding: Monitoring and evaluation are not clearly assigned
to any one organization, which hinders cost-effectiveness. Currently, BPA,
through its contract administration responsibilities, is responsible for
collecting project progress information from contractors. However, neither
the Council, BPA, ISRP, Peer Review Groups, nor CBFWA appear to have lead
responsibility for monitoring and evaluation of the overall effectiveness
of the Program that results from project implementation.
Recommendation: Assign to a single entity the primary
responsibility for project delivery and program performance monitoring and
evaluation. The entity primarily responsible for developing the Fish and
Wildlife Program should also be responsible for ensuring that monitoring
and evaluating the effectiveness of the Program occurs. Provide the
resources necessary to perform this function. The ISRP and Peer Review
Groups can supplement these efforts, but continuity and consistency are
critical to effective evaluation of project delivery and program
performance results.
3. Finding: Many fish and wildlife projects are annually renewed
and/or modified multiple times without receiving a thorough evaluation of
their effectiveness in meeting Program objectives. The 1996 Amendment to
the Northwest Power Act calls for the establishment of Scientific Peer
Review Groups to assist the ISRP in evaluating the scientific merit of
ongoing projects. The ISRP subsequently recommended that peer reviews be
conducted of continuing projects every three to five years.
Recommendation: Implement the ISRP's recommendation to conduct
peer reviews of ongoing projects. The input of the Peer Review Groups
would not only provide valuable scientific input, but it would also
provide additional capability to have project performance guide future
planning and procurement decisions.
VI. Implementation Plan
Implementation of the recommendations contained in this report will
ultimately require significant changes to the way the Columbia River Basin
Fish and Wildlife Program is currently implemented. Changes have been
recommended relative to procurement and contract administration. Planning
and monitoring and evaluation have been identified as areas where
additional improvements could occur that would strengthen cost-effective
implementation. Implementation of the recommendations may necessitate
reorganization, process reengineering, modifications to roles and
responsibilities, additional resources, and changes to policy or law. An
overview of these changes is provided below.
? Reorganization?Assess the feasibility of integrating COR
fish and wildlife contracting and COTR functions within the BPA Fish and
Wildlife Division. Perform organizational analysis needed to support
consideration of this strategy.
? Process Reengineering?Numerous process and procedure
changes will be needed in order to streamline the proposal review process,
establish more stringent information reporting requirements for fish and
wildlife managers and contractors, institute an annual planning process,
if possible, and develop and implement a comprehensive performance
monitoring and evaluation framework.
? Modifications to Roles and Responsibilities?Improving
teamwork between BPA, CBFWA, and the Council in administering contracts
and monitoring and evaluating project progress and results will require
changes to existing roles and responsibilities. In addition, focusing
stakeholder participation in the planning process, when possible, will
represent a more proactive role for CBFWA.
? Changes to Policy or Law- several of the recommendations
will require revisions to the Bonneville Purchasing Instructions. Other
recommendations will require changes to the Memorandum of Agreement and/or
Northwest Power Act, or new legislation.
By implementing these changes, the Council, BPA, CBFWA, and other fish
and wildlife stakeholders will 1) create greater accountability for
Program implementation, 2) establish a more cost-effective process for
implementing the Program, and, ultimately, 3) provide the foundation for a
more successful Program.
Decisions to implement recommendations contained in this report will
require an agency to take lead responsibility for organizing resources,
establishing timelines, performing supporting analysis, when necessary,
and, ultimately, championing the changes. The lead agency will vary
depending on the recommendation. In several cases, achieving successful
implementation will necessitate the cooperation of multiple groups. The
next step is to assemble representatives of the key stakeholders to
jointly develop a mutually acceptable, detailed action plan for
implementing recommended changes.
In general, the responsibility for implementing the recommendations
contained in this report can be summarized as follows:
? Procurement?Bonneville Power Administration
? Contract Administration?Bonneville Power Administration
? Planning?Northwest Power Planning Council, CBFWA, and independent
scientists
? Monitoring and Evaluation? Northwest Power Planning Council, CBFWA,
and independent scientists
Implementation timing and duration will vary depending on the type of
change required. For instance, adjustments to administrative processes and
procedures will tend to be achievable within a matter of weeks; changes to
roles, responsibilities, and organizational structure will typically
require several months to facilitate the transition process; and changes
to processes that require policy, statutory, or institutional
modifications can be expected to take 12 to 36 months to accomplish.
Taking into consideration the sequence and timing of annual Program
development and implementation activities, a general implementation
schedule is provided in Exhibit 5.
Exhibit 5, Implementation Schedule
By working as a team, the Council, BPA, CBFWA, and independent scientific
advisors can achieve this road map for improving the efficiency and
effectiveness of the Program implementation process. Each of these groups
and the public stand to greatly benefit from the successful implementation
of the recommendations contained in this report.
VII. References
- 1994 Columbia River Basin Fish and Wildlife Program, Northwest Power
Planning Council, December 14, 1994.
- 1995 Amendments to the Columbia River Basin Fish and Wildlife
Program, Northwest Power Planning Council, September 13, 1995.
- 1996 Amendment to the Northwest Power Act, United States Congress,
1996.
- Addenda to the Draft FY1998 Annual Implementation Work Plan,
Columbia Basin Fish and Wildlife Authority, July 15, 1997.
- An Integrated Framework for Fish and Wildlife Management in the
Columbia River Basin, Northwest Power Planning Council, April 10,
1997.
- Analysis and Development of a Project Evaluation Process, Charles C.
Coutant and Glenn F. Cada, Environmental Sciences Division, Oak Ridge
National Laboratory, January 1985.
- Bonneville Financial Assistance Instructions, Bonneville Power
Administration, October 1, 1994.
- Bonneville Purchasing Instructions, Bonneville Power Administration,
March 15, 1995.
- Comprehensive Review of the Northwest Energy System, Final Report
Toward a Competitive Electric Power Industry for the 21st
Century, prepared by a 20-member Steering Committee, December 12,
1996.
- Draft FY1998 Annual Implementation Work Plan, Columbia Basin Fish
and Wildlife Authority, June 4, 1997.
- Draft Guide to Project Peer Review in the Columbia River Fish and
Wildlife Program, Scientific Review Group, February 10, 1994.
- Memorandum of Agreement among the Department of the Army, Department
of Commerce, Department of Energy, and Department of the Interior
concerning the Bonneville Power Administration's financial
commitment for Columbia River Basin Fish and Wildlife Costs, September
16, 1996.
- Pacific Northwest Electric Power Planning and Conservation Act,
Public Law 96-501, 96th United States Congress, December 5,
1980.
- Review of the Columbia River Basin Fish and Wildlife Program as
directed by the 1996 Amendment to the Power Act, Independent
Scientific Review Panel, July 15, 1997.
- River Future, Summary and Guide for Public Comment for the Fiscal
Year 1998 Fish and Wildlife Project Selection Process, Northwest Power
Planning Council, July 15, 1997.
- Standard Template for Projects, Bonneville Power Administration,
June 26, 1997.
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