Grady-Gould, completed project in Jefferson, Desha. and Lincoln Counties. Chicot, Desha, and Drew, completed project in Chicot, Desha, and Drew Counties; and Fish Bayou, planned but not installed in Crittenden and St. Francis Counties. The Public Law 566 projects show the nature of channel work to be: Grady-Gould-78.0 miles of ditches and drains, 10.0 miles of natural stream alterations. Chicot, Desha, and Drew-32.0 miles of ditches and drains, 13.8 miles of natural stream alterations. Fish Bayou (proposed)-30.0 miles of ditches and drains, 5.0 miles of natural stream alterations. The appraisals on these projects show little or no impact on fish and wildlife resource values but very measurable gains to the rural and agricultural economy. The Arthur D. Little report summarizes findings on the fishery resources of the projects: "On the 36 existing projects evaluated, we find total destruction to severe diminution the immediate and still prevailing result on six completed projects, temporary and minor disturbance to modest recovery on 15 completed projects and no appreciable adverse effects on 15 completed projects. For the six proposed projects, one would be seriously destructive to existing and potential resources, one moderately but temporarily disturbing, three would experience no effect as no resource exists, and one would beneficially affect an adjacent lake." We take exception to the statement in the propaganda pamphlet relating to the review of project plans by the Congress. Contrary to their implication, the congressional committees having responsibility for approval of project plans do require an endorsement by the Congressman in whose district the project is located as a condition for committee approval. It appears quite obvious that this constitutes a continuing harassment of the watershed program by a small group who have no direct interest or responsibility in the projects they are attempting to stop. The Soil Conservation Service is very conscious of the responsibilities that go along with the conduct of a national soil, water, and watershed conservation program. It has long been the goal of the Service to conserve, develop, and improve the broad spectrum of America's natural resources and create a more wholesome, quality environment. Closely related to this is another goal-that of expanding economic opportunity throughout rural America. A better environment and better economic opportunity can do much to reverse or at least curb migration to blighted metropolitan urban centers. Some changes in the rural landscape are certain and needed if these goals are to be achieved. Some choices must be made, and compromises may be necessary. However, through careful planning and application of broad technical knowledge they can be achieved without serious degradation of the environment. We appreciate the opportunity to provide this information. The pamphlet is being returned, together with a report of field inspection and hearings conducted by the Subcommittee on Conservation and Watershed Development, House Committee on Public Works, which has just been printed. The report contains much interesting testimony by individuals and officials who are working closely with the watershed program. Sincerely, WILLIAM R. VAN DERSAL, ARTHUR D. LITTLE, INC., Cambridge, Mass., July 24, 1972. Mr. BOYD GIBBONS III Council on Environmental Quality, DEAR MR. GIBBONS: This long letter is a sincere attempt on the part of Arthur D. Little, Inc., to foster closer mutual understanding with CEQ of the contractual scope of work in assessing stream channel modifications, the substance of our draft report resulting from this assignment, the remaining effort to satisfy your needs and the requirements for this effort. In this response to your letter of comments dated May 23, 1972, we are guided by your original study prospectus, the contract, our proposal which became an annex to the contract, our draft report, many other reviewer comments, your page-by-page comments furnished on July 6, 1972, and our discussions in your office on July 6. At the outset, let me express my genuine regret that certain fundamental misunderstandings or misinterpretations of the scope and substance of our work for your Council have persisted. Much of this, it seems to me, results from differing perceptions of a complex problem and a continually evolving realization by all parties as to the basic and subsidiary issues involved. We attempt in the following pages to deal with all of these. YOUR REVIEW COMMENTS I. GENERAL BACKGROUND As we understand it, your foremost concern here is over lack of an in-depth examination of the assumption underlying channel programs or the validity of the fundamental assumptions on which the agencies base their programs. Please be assured that ADL did not deliberately avoid an in-depth examination and careful analysis of these underlying assumptions; on the contrary, we felt and still feel that these were not called for by the contract. We can in fact provide the in-depth examination and careful analysis of the underlying assumptions of the program, but to do so will require a recognition and appreciation of what has already been done, and what remains to be done. A distinction between a descriptive history of programs and an analysis of projects is crucial in this regard. We made this distinction in our annexed proposal, first in section II on the background situation. Then, in subsection 1, section IV, scope of work and procedures, which define the contractual obligation, we proposed to provide a history and description of programs, including the basie rationale of the several purposes intended to be served. Procedurally, we sought to evaluate other studies relevant to the history, description, and basic rationale of programs. In distinct contrast, subsections 2 and 3 of section IV deal exclusively with the analysis of the projects, rather than programs. In rendering our draft report, we had felt that we had in fact more than complied with the requirements dealing with the history, description, and basic rationale of programs. In fact, we felt that we had more than fulfilled the minimum requirements for a factual assessment of physical effects of projects and an analysis of economic merits of projects (subsections 2 and 3) by providing a detailed project description and plan formulation section on each of the 42 projects (a description, history, and basic rationale) although no such requirement was called for. Additionally, although the contract calls for only an evaluation of reports on six proposed projects, we provided a full field evaluation at very substantial additional expense. A. Organization of the report Our discussions with you indicated to us that your concern about the organization of the report is that the report is not issue-oriented in its organization. This is true. We had tried in the introductory section to our technical proposal and subsequently throughout the course of our work to draw the often-neglected distinction between an issue and a problem. It now seems clear that we have failed to communicate with you the fundamental perception that we had about our field work, analyses for you, and reports to you. This might best be described as one of trying assiduously to maintain an independent, unbiased, detached. and unemotional position with respect to issues while trying at the same time to get at the facts about the problems that have spawned the issues. You have placed great stress upon our supportive role in providing a factual assessment so that you might then deal with the issues. We still do not believe in making or escalating an issue if none is to be made or escalated. Nevertheless, we now understand your concern that the report is not organized around the issues you have identified and that the draft appears to lose sight of the primary concerns of CEQ; namely, the environmental issues surrounding the controversy. To correct this, we can completely restructure the summary findings section to highlight the issues you have identified at the outset, to relate them to the types of projects evaluated in the field, to draw upon these evaluations more precisely, and to separate findings by kind of issue and kind of project. We can also reorganize and rewrite major portions of chapters V through VIII in an effort to make them more issue oriented, to relate them to the projects by type, such as urban, rural, natural streams, manmade ditches, coastal plain, etc. As we have indicated, and as you have agreed, we can do so only to the extent that factual data or supportable judgments permit. We understand from our July 6 discussion that the first four chapters of volume I need not be substantially redone, although we do wish to consider carefully all comments about these chapters from you and other reviewers. We intend to correct any errors of fact, and, if possible, to clarity certain matters. In the light of this very substantial reorientation and restructuring of the report, and the effort that will be required to accomplish it, it seems useful to look for ways to cut back or eliminate superfluous or unnecessary tasks. This can be done in volume II, parts 1 and 2, in several ways, and at a very considerable saving in costs of the final report. Whether these should be done is a matter we would like your reactions to, but we list them as ways to reduce cost. First, it was not expected or required that we record and document attendance at field meetings. In fact, it was our own voluntary field strategy to conduct a "public" orientation session before field inspections and a "wrap-up" session after field inspections. We can eliminate nearly 100 pages devoted to this attendance record. Second, it was not intended or required that project maps be presented in the report. We voluntarily assembled and reproduced 50 maps at considerable cost in time and budget. These can be omitted in the final report. Third, as discussed above, the two evaluation report sections on project description and plan formulation were provided voluntarily and beyond the scope of our assignment with the feeling that they would add materially to an understanding of each project, and that it would serve to record on a project basis, as distinct from a program basis, the engineering techniques applied, the legislative history, the basic rationale and the planning arrangements that we were only contractually obligated to provide under the terms of subsection 1(a)–(d) that deal with programs. Substantial effort was also volunteered on the extent of citizen participation or involvement on a project basis, a requirement of subsection 1(d) on a program basis only. Upward of 150 pages of this material in volume II can be eliminated from the 42 project reports. Fourth, it was not intended or required that we evaluate six proposed projects in the field. These are the South Florida Conservancy District watershed project, the Yantic River project. Bayou Bartholomew. Fish Bayou, North Nashua, and River Rouge. We can materially reduce costs by eliminating any reference to fieldwork, resulting observations and footnote referencing on these six projects, and confine our analysis to the original intent of a reports evaluation. Well over 300 pages will be saved by these adjustments to remove material that is description, history and basic rationale of projects, and volume II can be bound in one part. These adjustments will serve to emphasize an issue-oriented factual assessment of physical effects, economic merits and financial arrangements consistent with subsections 2 and 3, section IV, of the contract, and will sharpen the issue-oriented focus on programs which you feel are most important. B. Documentation and use of existing literature You describe the most serious deficiency in the entire report (vols. I and II) as the lack of documentation. We have discussed this together before and since delivery of the draft reports. While our perceptions of documentation differ for a report of this kind, we need not belabor the matter further. We have promised a full and complete bibliography with the final report, and it can be subdivided by volumes I and II and the projects of volume II. As for footnoting, we can now appreciate your thoughts on this matter, having perused the report to CEQ on the "Quiet Revolution in Land Use Control." While we may not be able to match the extensive documentation of this report because of the different nature of the work, we will make footnote references to documents and other factual data and sources, rather than citing, as we did, the appropriate references in the body of the text itself. However, we feel it is neither required nor advisable to reference by name the source of any discussions, observations, opinions or other statements. In fact, this may not even be possible, since we took no tapes of our multitude of field conversations and made no attempt to identify individuals with statements. Additionally, such an approach could lead to a welter of disputes that would embroil us both in an endless controversy. In lieu of this approach, we must qualify statements in the text and will, if possible and appropriate, attribute statements, discussions and opinions to "a representative of an agency," or "on the basis of extensive interviews" or such similar reference which will indicate the source without revealing the person's identity. As to the citing of project examples to specific discussion in volume I, we have already made over 200 such references in the draft report, but we can add to this significantly in the final report and we will do so. Considered together, the required bibliography and footnoting to document the facts may well fill an additional 150 pages. As to the second aspect of this review subsection-the use of existing literature misunderstandings have probably been more acute than upon any element of the study. As we understand it, you wish us, where practical and relevant, to draw upon existing literature, to support or reinforce conclusions. Obviously, this must be done with great care to be certain that generalizations are not drawn that go beyond the factual data of the 42 projects and the limitations of the literature. We did in fact seek to acquire and evaluate other studies relevant to the history, description, and basic rationale of channel modification. We received and reviewed many more than the 11 documents you cite in your review comments, and we did in fact cite two of these highly inconclusive studies in our draft report. The 11th of your citations, the Wharton work, was received only after our rendering of the draft report, in response to your request for additional data. There must be a cutoff point for receiving and considering data. Adequate appeals for the relevant literature were made well before the rendering of our draft report. Data received after the draft report requires additional work to incorporate. Virtually all data received as a result of these appeals and solicitations were irrelevant to the 42 projects evaluated. A crucial aspect on this matter of literature evaluation is that there simply were not enough hours in the day within the time constraints imposed to evaluate all the material received, even if it had been relevant. The need to meet the March 31 deadline precluded as detailed a review of the literature as we would have liked. It may foster understanding to recall also that these good faith provisions of our proposal were written at a time when the CEQ-ADL discussions and negotiations were confined to the consideration of 15 existing projects and 5 proposed projects. While reasonable men may differ about performance, we earnestly suggest that you consider our performance in the context of the scope of work and our proposed response at the time this study was framed. I am sure you will recall the list of projects actually evaluated was extended from 20 to 36 only because we on our part volunteered to consider such additions based upon our experience in evaluating the first few-in New Jersey-on the list of 20. Ourcorrespondence at the time clearly documents this fact. With a doubling of project evaluations in the field, literature evaluations of necessity were relegated to secondary significance. Your critique of our work seems to neglect our willingness during the early stages of this work for you, to extend the number of field evaluations in your best interests. C. Academy of Natural Sciences data The difficulties of incorporating ANS data are now well known to both of us. In a previous letter to Dr. Patrick, for example, I cited the receipt of ANS material on the final day before going to press. Some of this was dictated to us by phone from Philadelphia in response to your own urgent work with Dr. Patrick on her summary statement. The marking of sampling stations by the Academy on our project maps could not be achieved because their information was received 3 days after our report had been printed. Nevertheless, and thanks to your kind assistance in clarifying the division of responsibilities, coupled with my letter to Dr. Patrick, our respective requirements are now clearly differentiated. In the execution of these requirements, we can try very hard to work much more closely with the Academy in the integration of their findings on fish and wildlife resources, habitat, and productivity into the final report. This, too, will take much more time than any of us had anticipated. A primary reason for deficiencies you cite in integration stems from the time constraints imposed. In this regard, two staff members of the Academy have now spent nearly 2 days in my offices and have had complete access to my entire files on this assignment. They returned to Philadelphia with a 50-pound carton full of documents from my files and to the best of my knowledge have all the information and data for their purposes that I had collected. As I have pointed out in my letter to Dr. Patrick, Arthur D. Little, Inc., has a critical responsibility to review the Academy's work for professional substance and the detail that you now require. We will employ every reasonable means to do so. D. Previous CEQ comments I am truly sorry about the misunderstandings engendered over your advanced review comments, primarily occasioned by time constraints. We received 468 separate written comments on our first rough draft field evaluation reports from you. You will recall that these reports were largely dictated in rough draft and voluntarily submitted to you and the advisory committee as a result of your request in the meeting of December 10 for 5 or 10 of our early drafts. While we were under no contract obligation to comply, your insistence subsequently to review drafts of all 42 project reports resulted in our submission of nearly 1,000 pages of draft material for your advance review. In summary, we considered many of your comments very perceptive and appropriate and we reflected them in the final draft report. Others were not incorporated for a variety of reasons. Some, for example, were answered by later comments in the report. Others would, in our opinion, have required so much additional research to answer that they were clearly beyond the scope of our work. Still others could not be incorporated without, in our view, raising questions about our objectivity. I would be pleased to go over this list of comments and our reasons for the disposition of each at your convenience. We now have specific comments on the final draft. We will give all of these very careful consideration. However, there may be instances where we cannot accept your comments, possibly for the reasons cited above. All project reports can be closely reviewed in the light of your earlier and more recent comments and the comments of other reviewers. In view of the experience we have both gained in an evolving understanding of the several problems surrounding this issue, we can and will be acutely sensitive to the distinction between hard facts on the one hand and conjecture, surmise, opinion, observations, judgments, and suppositions on the other hand. It will be a time consuming and painstaking effort to sort out, reword, document, or eliminate from nearly 1,000 pages of text, but given enough time it can be done. E. Advisory group, agency, environmental groups, and other comments As a result of events to date, little more need be said about reflecting wellconceived, objective and rational critiques into our redrafting effort. There is one point, however, which needs clarification in the interests of furthering our mutual understandings about what we have both gone through and what lies ahead. You quote from our letter which requested additional funds-third modification of the contract-based in part on the need for additional time to reflect adequately your earlier comments in the detail and depth suggested and to permit all data, observations, and viewpoints to be carefully recorded and reflected. I am sure that you will recall this letter request was presented to you at a time when we were under the impression that we would render a 25-copy report for your internal staff review, review of the advisory committee, and review by our consultant. You will recall also that the additional funds were made available subsequent to our fund request under modification No. 3 conditional upon furnishing 185 copies of this report. While the extra cost of the production run was not substantial, and could be included within the funds requested, our fund request did not allow for incorporation of comments from a public review. The release of the draft report for public review increased the number of comments to be reflected by an order of magnitude over that which was the basis for our fund request. As a consequence, while we can now reflect, where appropriate, the review comments of perhaps 45 agencies, organizations, and individuals, we are only contractually required to reflect and consider your own, those of the advisory committee and those of our consultant. F. Consistency and balance As authors of a rather large report prepared in haste, we are indebted to any and all reviewers who have cited instances of inconsistency or imbalance in the treatment of any aspect of the subject. The handicaps and difficulties under which we operated in trying to serve your best interests now seem quite well known-except to certain unsympathetic individuals, and each member of the advisory committee has recognized serious faults in the study design relative to the resources made available for its accomplishment. Perhaps we have both learned something about the subjective element of objectivity as well. Like esthetics, objectivity may indeed depend upon one's point of view. We have both read the comments, ranging from "unusual objectivity" to "total lack of objectivity." Our only response to your comment about balance and tone is to say that we will try very hard to convince all readers that we are in fact neutral. |