PROGRAMS AND PLANS--Hydrologic Activities to be Excluded from the Federal-State Cooperative Program
In Reply Refer To: December 5, 1983
EGS-Mail Stop
WATER RESOURCES DIVISION MEMORANDUM NO. 84.21
Subject: PROGRAMS AND PLANS--Hydrologic Activities to be Excluded from the
Federal-State Cooperative Program
The basic mission of the Water Resources Division (WRD) is specified by law
and other mandates and, therefore, does not readily change. On the
other hand, hydrologic conditions, hydrologic problems, and the public
awareness of these problems do change, and as a result our activities
change with time. These changes make it important that criteria used to
evaluate WRD activities be reviewed and defined on a regular basis.
The current trend toward shifting responsibilities from Federal to State
agencies to fund development and for managing the water resource could
conceivably influence the emphasis of the Federal-State Cooperative
Program. Thus, it is especially important that periodically the
criteria for selecting activities for the Federal-State Cooperative
Program be reviewed.
Those activities considered to be of highest priority and greatest interest
are reviewed and redefined each year. Less attention has been placed on
the other end of the scale; that is on those activities that should be
excluded from WRD programs. At any time the Division needs to guard
against expending its resources on less important activities, but
especially at times when funds and manpower are under stress.
The attached staff paper reviews and discusses criteria to be used to
decide which hydrologic activities are not appropriately included in the
Federal- State Cooperative Program. The discussion paper provides
policy guidelines, examples, and references to existing directives that
should be used, along with other WRD policy statements on high priority
issues, in the formulation of new programs.
/signed/
Philip Cohen
Attachment
Distribution: All Professional Personnel
=========================================
Attachment
HYDROLOGIC ACTIVITIES TO BE EXCLUDED FROM THE
FEDERAL-STATE COOPERATIVE PROGRAM
Introduction
The task of defining guidelines for rejection of hydrologic studies and
data collection proposed by Water Resources Division (WRD) Districts for
inclusion in the Federal-State Cooperative Program might be viewed as
the negative counterpart of identifying those activities to be accorded
the highest priority in the program. In other words, rejection criteria
would have to be based on some definition of the lowest priority.
One criterion might entail a definition of hydrologic activities that are
devoid of merit in the sense that the data or information derived from
them would be worthless or nearly so. However, the selection and ranking of
hydrologic studies and hydrologic data collection that are of lowest
priority is even more subjective than the selection of highest-priority
activities. High-priority program issues are so defined in part because
of their relation to water problems that are wide-spread geographically.
As applied to areal descriptions or interpretive
studies, geographically limited occurrence of the water problem to which
they were addressed would be a necessary criterion for rejection, but
any one of many factors might make a given project of limited geographic
extent and occurrence a very desirable addition to the Federal-State
Cooperative Program. Considerations of geographic distribution,
however, are not applicable to the acceptance or rejection of a given
data station.
The list of high-priority activities is rooted in the Division's
perception of national and regional water problems, which are the
aggregate of local problems, but rejection criteria cannot be based
solely on a limitation in the utility of the resultant data or
information in space or time, because of the possibility that
information of limited areal extent, or data at some point, might be
critical to the understanding and eventual solution of a particular
hydrologic problem.
In the past it was fashionable to judge the worth of proposed activities
in terms of Federal interest--a concept that commonly had been equated
with "national" or "interstate." The Federal-interest notion has,
however, become less useful with time, as Federal funds are no longer
reserved for very large, or "national" projects, Federal dollars have
pervasively entered all levels of government and all aspects of life.
Thus, it has become increasingly difficult to define an absence of, or
some minimal degree of Federal interest. The spectrum of enterprises and
activities supported by Federal dollars is so broad, and so many of them
take on national significance only by aggregation
of a myriad of site-specific and local concerns, that by analogy
practically any and all local and site-specific hydrologic data can be
said to have "Federal value" and, therefore, to fall within the Federal
interest. Is there less Federal interest in water-supply wells for
small rural communities than there is for wheelchair ramps on city
sidewalks?
In contrast, there are: (1) Legal and administrative constraints deriving
from the Organic Act, the appropriation language, and "the intent of
Congress," plus the amplifying rules and procedures promulgated by the
Department and the Survey (manuals, and so forth) that contain explicit
rejection criteria or provide the framework for them; (2) statements of
objective and mission that allow the exclusion of activities not
included by such statements;
(3) judgmental determinations that a given proposal would be technically
in-feasible; and (4) management considerations.
The criteria and guidelines that follow, as well as the discussion intended
to illustrate and amplify them, should be applied to program proposals
for work under the Federal-State Cooperative Program regardless of the
funding mechanism. They should be applied whatever the funding
situation, 50-50 matched funds, Federal funds against direct services
credit, or 100-percent repay.
Relation to High Priority Program Issues
High-priority program issues, as listed and defined in WRD Memorandum
83.52 for example, describe the kinds of interpretive studies that will be
given preference for funding in the Federal-State Cooperative Program.
Data collection activities generally are not uniquely related to such a
priority list. By implication, however, kinds of data that would
contribute to, or provide the foundation for, high-priority program
issues take on higher priority than data collection devoid of such a
relationship. If a proposal for new work does not fall within the realm
of any of the high-priority categories, it should be examined critically
and tested against the criteria for exclusion.
A long list can be compiled of activities that are generally considered
to be of low priority. In some situations good reasons exist for
excluding them from the Federal-State program; in others, they might serve to
complement other program elements, or to fill a critical gap in the spectrum of
hydrologic information. The list includes, but is not confined to:
compilation of drainage areas, preparation of bridge site reports, and
sampling and analysis of waste treatment plant outfalls. None of these topics
can be categorically rejected. In some hydrologic situations, or if the
understanding of the hydrology is minimal, each could be relevant, and
in some cases, provide essential hydrologic data or information.
Legal and Administrative Constraints
1. The Organic Act prohibits the undertaking of work for private parties or
corporations. By extension, this restriction can be applied to joint-
funding agreements with private parties or corporations. Although
language in the Appropriations Act for FY 1983 allows for funding of
Survey work from private sources, the line items for Federal-State
water-resources investigations are presumed not to be affected.
2. Appropriation language in recent years has referred to "...water-
resources investigations carried on in cooperation with any State or
municipality." This has been interpreted to mean an agency or entity
having taxing authority or a public institution that is an integral
part of such tax-levying entity. An entity that did not meet such a
definition would not be eligible to enter into a joint-funding agreement.
For example, the University of California operates the Los Alamos
Scientific Laboratory in New Mexico under contract for the U.S. Department
of Energy. While the University would be an appropriate cooperating
agency for work in California, in New Mexico it is a contractor to a
Federal agency and not an extension of that State's government.
3. Cooperative (joint) funding cannot be used for hydrologic activities out-
side the United States and its associated commonwealths and trust
territories.
4. Hydrologic investigations, the conduct of which would violate existing
laws of statutes, are to be rejected. (See WRD Memorandum 81.53.) For
example, investigations that might have significant adverse effects on
public health and safety, such as the introduction of toxic or hazardous
materials as hydrologic tracers, or adversely affect endangered or
threatened species, should be rejected. Investigations that would
adversely affect national landmarks, antiquities, or archeological sites
should be rejected.
Policy and Mission Constraints
1. The long-standing and firm Division policy not to compete with private
industry (See WRD Memorandum 79.42 and memorandum from Chief Hydrologist,
with enclosures, to Regional Hydrologists and others dated April 5, 1976,
on "Programs and Plans--Competition with private industry.") precludes
consideration of any work devised for or submitted competitively with
private industry.
2. Work will not be undertaken (except perhaps under certain court-ordered
situations or under special situations negotiated with and specifically
approved by the Chief Hydrologist and the cooperator) in which the data
and reports therefrom cannot be made public.
3. Given that in broad terms the mission of the Water Resources Division, as
conveyed or implied in various laws and other statements, is to appraise
the Nation's water resources, any work proposed for joint funding that is
not within that mission would not be acceptable. For example, a State
Highway Department might propose joint funding of engineering geology
necessary for highway design, but without hydrologic implications. Such
work should be rejected.
4. Work that is more appropriately done by private industry or another
governmental agency. The scope of proposed work, and its relation to
the mission of the Geological Survey to "appraise the Nation's water
resources," must contribute to the determination of appropriateness.
If it is clearly in the public interest that hydrologic data be collected
or hydrologic information be generated in an unbiased, objective manner
and that there is a clear public need for the data/information, then it
is appropriate for the Geological Survey to consider the work. The need
for continuity in time-series data is especially important in such a
determination; continuity can best be assured if the data are collected,
disseminated, and archived by an organization with a recognized expertise
and the stability necessary to provide a long-term standardized data
operation. If these tests are not met, or if the work cannot reasonably
be judged a part of appraising the Nation's water resources, than it may
be more appropriately within the purview of the private sector or other
governmental agencies.
Even though a cooperating agency might prefer that a given piece of work
be done by the Water Resources Division--whether it be flow conditions at
a bridge site or a waste outfall, or the location of a supply well for
a new subdivision--the worth of the resultant hydrologic data, and
especially further interpretations thereof, must be critically evaluated
before deciding to accept or reject such work. However, if the purpose of
the hydrologic work is dominated by design and engineering considerations
of a facility or structure, or if under these conditions and constraints
the worth of the data or information does not meet Division standards, then
the hydrologic work should not be undertaken as part of the cooperative
program. For example, consider the opportunity to collect ground-water
data in connection with dewatering necessary to excavate for the foundation
and substructure of a large building, perhaps one being built by a
cooperating State or local agency. Observation wells might be available,
along with other appurtenances and sources of related data. However, if
the dewatering had to be done in such a manner that would preclude the
estimation of aquifer parameters--perhaps variable discharge rate, or
multiple discharge points--rejection of the work probably is in order.
Indeed, if the dewatering cannot be regulated in such a way as to make it
a useful aquifer test, the work should be rejected.
If a major part or primary thrust of the work consists of engineering,
economic, or other determinations, judgments, or opinions, it is more
properly done by the private sector and should be rejected by the Division.
This is not to say that economic or engineering aspects of resource
appraisal or development are to be excluded from the cooperative program,
or that economic or engineering ramifications per se can or should be the
basis for exclusion; rather that engineering or economics must be sub-
sidiary to hydrologic or water-resources considerations.
This guideline is especially difficult to express. A definition written
from the government point of view is likely to be considered self-serving
by industry and vice versa. The key judgment involves the anticipated
worth of the resultant data, and the need for those data in ongoing
programs or as part of a network. This guideline must be applied
flexibly, and implemented gradually, because the availability of private-
industry capability varies a great deal from one State to another, and
because of historical factors in the development of the cooperative
program.
5. Information Value
Activities that will produce little hydrologic information, or informa-
tion of low value, should be rejected. Activities that would duplicate
known facts or information are to be rejected. This obviously requires
a distinction between refinement and duplication of information, and
would not apply to conditions known or thought to vary with time.
Consider the case of a well field to be developed in an area where the
subsurface geology is well known, but where head distribution and
hydraulic properties of the aquifers and confining beds are poorly
defined. Initial drilling and testing of the first few wells are likely
to have a high information content, and depending on the general under-
standing of the flow system, information of high value. Thus, it would
be appropriate to monitor the initial drilling and testing carefully to
insure that head distribution is well documented and that properly
designed and conducted aquifer tests produce good information. However,
at some stage in well field development and expansion, data on individual
drill holes takes on as a primary objective the design of casing and
screening so that yields can be maximized and drawdowns can be minimized.
The generation of continuing data on drawdown, pumpage, etc., provides
justification for continuing Division involvement, but unless such
opportunity exists, at this point the collection of drill-hole data is
no longer an appropriate cooperative-program activity, including
recognition of direct services credit.
The key point in this guideline relates to the duplication of known facts
or information. While it may be well within the cooperator's mission and
objective, and may indeed be essential to that mission, to duplicate the
hydrologically significant information for other reasons (for example,
engineering requirements), when the generation of new hydrologically
significant data or information decreases appreciably or vanishes, the
activity is no longer appropriate for Division involvement.
Technical Feasibility
Rejection criteria related to technical feasibility of proposed work
(a) must be considered in a very flexible manner,
(b) must rely on and presume that those persons responsible for acceptance
or rejection of proposals have access to the technical expertise and judgment
consistent with high scientific standards of the Geological Survey,
(c) must be made in light of the capabilities of the Division as a whole
to advance the state-of-the-art, and
(d) must consider the ability and willingness of the organization to
assign the requisite scientific talent to the proposed work.
In some cases it is necessary to reject proposals for cooperatively funded
work because there is inadequate scientific understanding of the phenomena
of interest to meet the stated objectives. In some cases the research
necessary to gain an appropriate degree of understanding is either outside
the purview of the Water Resources Division, or chemically and physically so
complex that a major research effort, and consequent program redirection,
would be required to achieve the necessary degree of understanding. This
situation is illustrated by a recent proposal to model the transport of
nitrates in ground water beneath an area where extensive applications of
nitrogen fertilizers take place. The proposal had to be rejected
because of chemical changes (including changes in the mass balance) in
the unsaturated zone and consequent uncertainties about the magnitude
and chemical nature of the very diffuse input to the ground-water
system. The project would not have been rejected if it had been proposed
as a research project with provision for adequate funding, time, and talent.
The conduct of basic research in the Federal-State program is to be en-
couraged, provided both parties fully understand and appreciate the risks
and uncertainties of the research and are fully prepared to dedicate the
financial and human resources to the quest for knowledge.
Questions of technical feasibility are most commonly raised by inconsistencies
between statements of objectives and descriptions of approach in areal,
topical, or applied-research investigations. Rejection may not be necessary
if a flexible position is taken by both proposers and reviewers for accepta-
bility. It may be possible to adjust and modify the objectives, or to amplify
and strengthen the approach (in some cases with appropriate adjustments in
effort and funding) and arrive at an acceptable match between objectives
and approach.
Technical feasibility frequently involves the time necessary, given a
reasonable level of effort and funding, in which to generate and verify the
data necessary for a given investigation, and fit those data within an appro-
priate conceptual, analytical, and/or numerical simulation. In many cases the
cooperating agency lacks sufficient understanding of the investigational
process to appreciate the time and effort necessary to achieve a given
objective. In such situations, either the direction of study and level of
funding must be extended, or the work should be rejected.
Management Considerations
Although management considerations may be considered somewhat subjective, they
are related to the general plans and concepts of the Division in terms of
program effectiveness and organizational effectiveness.
National program balance
Inasmuch as the only vehicle whereby the Division can provide reasonably
comprehensive and complete coverage of the hydrology and water-resource
conditions of the entire Nation is the cooperative program, it follows that
the Division has an obligation to strive for a reasonable geographic balance
in that program. In other words, if a wealthy State such as California,
Florida, or some other State wished to participate in the program with a very
large sum of money, and the necessary increase in Federal matching funds could
not be obtained, at some point the acceptance of such work would operate to
the detriment of the overall program, because other needs for information
could not be met within the limits of the appropriation. Objective criteria
at which distortions of program balance would be detrimental are elusive at
best. There seems to be no practical way of combining the myriad of factors
that enter into such judgment. Nevertheless, if proposals for work would
require a level of funding that necessitates "robbing" programs in other
States, the proposals should be rejected or scaled down. Similarly, if the
direct credit contribution from the State and local agencies approaches a
level in which technical competence and operational efficiency within the
offices of the Division would be appreciably weakened, such proposals should
be rejected.
Shifts in geographic balance can very well result from program emphasis on
high-priority national concerns that are not evenly distributed geographically;
for example, water for energy self-sufficiency, or water for increased food
production, and the hydrologic impacts thereof. Such issues can and should be
identified in advance and should be specified as line items in the budget,
rather than allowing the program in some parts of the country to deteriorate
in order to expand a few priority issues having limited geographic scope.
This, however, becomes a problem in the definition of national-program goals
rather than defining rejection criteria.
Maintenance of program balance should be a goal of Division management; the
process of acceptance or rejection of a particular project or data station
is but a minute step toward the larger goal.
Direct services credit
Criteria for rejection of proposals for cooperatively funded work by the Water
Resources Division apply also to work by a cooperating agency for which
direct-services credit might be offered. In addition, direct-services credit
should not be granted for major capital expenditures by the cooperating agency,
and proposals predicated on such expenditures should be rejected. (See WRD
Memorandum 71.17.) This applies especially to major capital expenditures such
as the purchase of well-drilling equipment. For example, the one-time cost
would be inappropriate; however, the fair market value of a use rate or a fee
for services is appropriate.
Employee safety
Proposals for work, whether in the Federal-State program or other program
elements, that would place employees in an unsafe environment should be
rejected. Although a number of Division activities involve some measure of
personal risk, and greater risk at some times that at others, work that would
incur an unacceptable level of risk should be rejected, whether it might
involve streamflow measurements from structurally unsound bridges, or
excessive exposure to toxic chemicals.
8/1/99
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The following memos referenced are obsolete or superseded:
71.017 Obsolete
79.042 Superseded by 84.036
81-053 Obsolete
83.052 Obsolete