1

CRAHG ISSUES with 2013-14 Budget and Work Plan Presented to the BAHG

General comment: It is difficult, if not impossible, to provide meaningful comment on the proposed FY 2013-14 

budget and work plan when 1/3 of the work plan is missing and presumably still in development. The 1/3 that is 

noticeably absent pertains to cultural resources, but given the past history of this program that is not entirely 

surprising, but remains troublesome. Recommend including a budget estimate/placeholder for the GCMRC 

cultural program in the draft budget submitted to TWG.

The following are specific CRAHG comments on the 2013-14 budget and work plan as currently presented:

GCMRC

• Previous CRAHG and other stakeholder concerns have been expressed about the unilateral decision by 

GCMRC/NPS to truncate the cultural resource monitoring program that was in development by GCMRC. 

The CRAHG, Technical Work Group, and Adaptive Management Work Group approved the development 

and pilot implementation of the cultural resource monitoring program proposed by GCMRC with a 

significant amount of funding expended in the development of this program since 2004. During the past 

two years, however, this monitoring program development has been in hiatus without sufficient 

explanation or justification back to the stakeholders. Not only does this situation call in to serious 

question the role of stakeholder review and approval in GCMRC program development and 

implementation, but it also means that monitoring of valuable cultural resources is not occurring and the 

threat of damage and/or permanent loss to these non-renewable resources is eminent. The CRAHG 

strongly encourages the refunding and reimplementation of the cultural resource monitoring program by 

GCMRC.

• The CRAHG would also like see a geomorphological criteria applied to any archaeological monitoring done 

in the canyon(s). These criteria would be developed following the work done by Pederson and Damp.

• Why are the tribal monitoring programs not being integrated along with those of GCMRC & GRCA?

• Overall lack of detail on tribal integration especially with the renewed focus on terrestrial monitoring 

(including TEK issues); in fact tribal integration is completely absent. Recommend more emphasis of 

terrestrial zone. It appears that the Riparian program is fundamentally changing from what had been 

developed while moving towards a core monitoring program. Will all of the sampling protocols and 

remote sensing be terminated?

• It is disconcerting that with all the recent attention to traditional ecological knowledge and its beneficial 

application to the AMP that it is not identified within GCMRC’s work plan for the next two years. Are the 

tribes being asked to wait another two years before the program decides to approach integrating TEK into 

the science program? The CRAHG strongly encourages GCMRC to develop and implement a pilot TEK

project in FY2013.

• Where are the mechanical removal projects?

Bureau of Reclamation

• It is unclear what the Bureau of Reclamation intends to implement under the Treatment Plan line item 

(and what happened to the last couple of years funding?). $515,000 slated for Treatment Plan but no 

explanation on how or toward what this funding is intended. The Bureau of Reclamation has not 

implemented any activity under the treatment plan since 2010 and the CRAHG is concerned that valuable 

resources are being threatened and perhaps irretrievably lost due to Reclamation’s indecisiveness and 

negligence. Reclamation needs to specifically explain their intention on how this funding is to be 

employed toward maintaining their compliance with the programmatic agreement. At this point in time 
2

the Bureau of Reclamation has been seriously out of compliance since 2010. The CRAHG would also like 

the Bureau of Reclamation to explain what has happened with the funding slated for the treatment plan

from previous years; specifically 2011 & 2012. Reclamation also needs to detail the process for integrating 

the tribal perspectives into the treatment plan; an integration that the tribes have requested for a decade 

or more and has not yet happened.

• $91,000 for National Park Service for cultural resource monitoring: please provide the intended scope of 

this monitoring and how or whether it fulfills a Reclamation responsibility under §106 and the

Programmatic Agreement. The Bureau of Reclamation needs to explain why the development and funding 

of this monitoring program was not vetted through the signatories to the programmatic agreement or the 

AMP stakeholders. The CRAHG has serious reservations about the development of a modified cultural 

resource monitoring program that is being negotiated between the Bureau of Reclamation, the National 

Park Service, and Grand Canyon Monitoring and Research Center without the participation of the other 

stakeholders to this program. Without the involvement of the stakeholders or the signatories to the 

programmatic agreement it is uncertain that there will be consensus on whether the monitoring program 

developed meets Reclamation’s compliance responsibilities or the needs of the GCDAMP.

• Noticeably lacking from Reclamation’s budget is funding to implement activities defined under the 

Memoranda of Agreement for the Non-native Fish Control and the High Flow Experiment Protocol. How 

much funding is Reclamation anticipating for each of these MOAs to remain in compliance? What is the 

tribal component to implementing compliance with these MOAs? How is the HFE-related monitoring 

being accounted for in these budgets. There was an explicit commitment made by Reclamation during the 

preparation of these MOAs, but where is the follow up in these budgets and work plans?

• Why is there not anything on the CPI for the Tribes?
Report of the Cultural Resources Ad Hoc Group (CRAHG)

Motion: In an AMWG motion passed at the 24-25 August 2011 meeting, the AMWG directed the TWG to 

reconstitute the Cultural Resources Ad Hoc Group and make recommendations to the AMWG on Issue

#3 at its February 2012 meeting. Issue #3: AMWG indicates its intention to make a recommendation to 

the Secretary on the following questions: How should the program fairly treat conflicts of cultural 

values, specifically those involving Native American perspectives? How will tribal values be monitored 

and tracked in this program?

The CRAHG met on 23 January 2012 to discuss these two questions and how to respond to the Technical 

Work Group. The CRAHG recognized that whatever recommendations the ad hoc group generates and 

brings back to the TWG and is ultimately reviewed and acted on by the AMWG could and probably will 

be significantly affected by the new Department of the Interior’s Policy on Consultation with Indian 

Tribes issued in December of 2011 and the subsequent Secretarial Oder 3317 issued on December 01, 

2011. The following represents a progress report to the Technical Work Group concerning the outcome 

of the CRAHG meeting.

Recommendations:

How should the program fairly treat conflicts of cultural values, specifically those involving Native 

American perspectives?

1. AMWG/TWG should spend more time and effort at trying to achieve understanding and

consensus among the stakeholders regarding issues where conflicts of cultural values are 

apparent.

• Agreement by AMWG to work harder (i.e., good faith effort) to achieve consensus

• Federal agencies (e.g., BOR) should be transparent about why they are making certain 

decisions and provide this rationale back to the tribes when the tribal perspectives are 

not honored.

• Federal agencies should take the initiative to begin a dialogue regarding emerging issues

to reflect their sincerity in working collaboratively where conflicts of cultural values are 

relevant.

2. Respect each stakeholder’s perspective and position

• Acknowledge and foster increased respect among stakeholders (at all levels)

• Acknowledge and accept that some stakeholders may have values and perspectives that 

are at odds with non-western views; respect these perspectives and be willing to 

objectively listen.

3. Listen – actually “hear” and understand what is being said (effective communication)
2

• Continue talking, talking, talking: It makes a huge difference in understanding and 

through effective communication new options can emerge.

• Dialogue among and between stakeholders is critical to successful communication. 

Discussions among stakeholders do not always need to be issue oriented. Non-tribal 

stakeholders appear to not understand various expressed tribal values regarding the 

Grand Canyon and the Colorado River ecosystem.

4. Acknowledge, accept, and respect philosophical differences regarding the ecosystem that are 

represented by the various stakeholders.

• Presentations by individual stakeholder groups are very productive. Stakeholder 

presentations should be recorded for use as educational tools for new stakeholder 

representatives to the AMWG/TWG and new scientists employed by GCMRC.

• Educate about the values beyond those from a western scientific perspective

• Educate about tribal issues and concerns.

• Educate AMWG/TWG stakeholders about “tribal values,” what these values mean, and 

that a monetary value or quantitative value cannot be placed on these values.

5. Work to rebuild a constructive dialogue and trust around the AMWG/TWG tables. There 

appears to be plenty of mistrust among and between stakeholders in this program.

• DOI needs to work at rebuilding trust among the stakeholders.

6. Develop a dispute resolution process for use in AMWG/TWG venues. This process should seek as 

its goal to achieve consensus. It should focus on educating and understanding each others’ 

values and perspectives. The dispute resolution process should be utilized before going to a vote 

on any motion. It also needs to address situations where the conflict of cultural values involves a 

stakeholder group and the decision-maker (Secretary of the Interior).

• Acknowledge and educate about the nature of the Federal government’s relationship 

with American Indian Tribes. This should be a shared responsibility between agencies 

and tribes.

• Acknowledge that Federal & State agency constraints exist that may conflict with tribal 

perspectives and values, and that it may not be possible to achieve what is being 

requested. In such cases, we should ask whether other recourses exist.

• Articulate the philosophical underpinnings for tribal consultation; the rationale.

• Institutionalize a dispute resolution process for the AMP that can be used as a last resort 

prior to litigation or taking concerns to Secretary’s Office.

7. Devote one full day where AMWG stakeholders share their various cultural perspectives about 

the Grand Canyon and the Colorado River ecosystem.

• Spend time with Native American stakeholders on their reservations to experience and 

begin to understand individual tribal cultures. These could be done as day trips designed 

to foster education, understanding, and appreciation.
3

• Conduct day trips on the river (maybe in conjunction with TWG/AMWG meeting at the 

dam).

• Create more meaningful opportunities for interaction beyond the “official” AMWG/TWG 

meetings and their respective agendas. A TWG/AMWG river trip may be appropriate, 

but tribes should take a principal role in developing the agenda so that it is not just a 

litany of science projects (see also below).

• Utilize retreats as a method for resolving conflicts of value

• Have each stakeholder Tribe host a retreat to discuss their assets

How will tribal values be monitored and tracked in this program?

1. A traditional ecological knowledge (TEK) integration process has been initiated and should 

be integrated into the Grand Canyon Monitoring and Research Center’s science program.

2. Cultural sensitivity workshops and/or training sessions would be opportunities to promote 

knowledge about different perspectives and mutual understanding.

• Two prong approach – joint TWG/AMWG river trip with Tribes setting the agenda 

and AMWG/TWG meetings at Tribal homelands.

3. Define basis (metrics) for determining success. This needs to be more than just counting the 

number of consultation meetings; it needs to evaluate successful resolution of conflict 

issues.

4. Stakeholder meetings in Page, AZ with a visit to the Glen Canyon Dam and a one day river 

trip to the Glen Canyon reach and the Dam.

5. Stakeholder meetings at Grand Canyon National Park

6. River trips with Tribal representatives very important coupled with stakeholder participation 

in tribal sensitivity workshops held in the respective tribal community. Feedback evaluations

by stakeholders who participate in tribal sensitivity workshops. Sensitivity training for 

GCMRC employees and contract scientists equally important.

7. Incorporate reflexivity into GCMRC’s science program

8. Annual report that tracks efforts at sensitivity sharing of cultural values among stakeholders, 

tracks conflicts of cultural values that emerge within the program, and efforts at tribal 

consultation to resolve conflicts.