The Importance of Defining Technical Issues in Inter-agency Environmental Negotiations

We studied the role of technical clarity in successful multi-party negotiations. Our investigations involved in-depth interviews with individuals who were the principal participants in six consultations conducted under the Federal Energy Regulatory Commission's (FERC) hydroelectric power project licensing process. Technical clarity was especially important in the cases we studied because they concerned questions that were science-based. The principal issues in the six cases were fish passage, instream flow for fish habitat, and entrainment of fish in hydropower turbines. We concluded that technical clarity was one of the most critical elements in these conflicts. The most successful negotiations were marked by a shared understanding of technical issues among the parties.

INTRODUCTION

Technical clarity in negotiations over environmental issues involves understanding the science-based aspects of a project, including the professional value judgments that must be made and the technical facts. Technical clarity is achieved when there is agreement on values and facts. Technical values include issues such as the resources influenced by the project and the geographic extent of project effects. Resolving these value questions requires defining the nature and extent of benefits that may be gained from the negotiation. Technical facts include issues such as the level of flow that will provide fish habitat and the timing of flow releases to maximize power production. Resolving the technical fact questions determines distribution of these benefits to each party.

To determine the relation between technical clarity and successful negotiations, we studied six consultations conducted under the Federal Energy Regulatory Commission's (FERC) hydropower licensing process. These consultations were undertaken between 1980 and 1989. Although the procedures for FERC consultation became more formal after passage of the Electric Consumers Protection Act of 1986 (ECPA; 16 U.S.C 791 et seq.), the negotiations we studied were typical of most environmental conflicts in that the parties were expected to work out acceptable means to protect fisheries and recreation values without benefit of explicit rules to guide the process or evaluate the solution they reached. The consultation procedures for all the cases we studied required the applicant for a license to consult with state and federal fish and wildlife agencies and to report the results of those consultations to the FERC. The FERC issued licenses for the projects with terms and conditions that usually reflected the results of the consultation (Kerwin 1990). The principal issues in the six cases were fish passage, instream flow releases for fish habitat, and entrainment of fish in hydropower turbines.

These issues are very common in FERC hydropower licensing consultations because hydroelectric projects almost always involve damming a stream, bypassing the stream through a pipe (called a penstock), and dropping the water back into the stream through a turbine that generates electrical power. A hypothetical project is shown in Figure 1 to illustrate that a hydropower facility could completely block the upstream migration of fish unless suitable facilities for fish passage are included in the project. Figure 1 also illustrates that the flow in a bypassed reach of stream could be significantly reduced when water is routed through the penstock to the powerhouse. In some projects, the turbines are incorporated into the dam itself (resulting in no bypassed reach) and in others the bypassed reach can extend for several miles. In addition, when water is directed through the turbines, flow is increased below the powerhouse. This fluctuation in flow can be dramatic, causing damage to the fishery and altering the bed and banks of the stream. Finally, fish that pass through the penstock and turbines can be injured or killed.

How to construct and operate a project so that these effects are minimized is the question at the heart of most FERC hydroelectric license consultations. For example, from 1980 through March of 1983, 59% of hydropower licenses contained special articles governing instream flows (Kerwin 1990). Instream flow conditions were included in 80% of the licenses issued during 1985 (Kerwin and Robinson 1985). Answering the question of how to minimize environmental damage is a technical problem amenable to scientific analysis. Although scientists can analyze the problem, the best course of action is not beyond dispute. As Patterson observed about management of California's Central Valley Project, "This will not be just a technical decision. Any program has to be workable politically" (quoted in Burby 1994:44) Ozawa and Susskind (1985) found that even if specific points are agreed upon in environmental negotiations, it is common to disagree on how to study the problem and how to interpret the results of studies. The findings of our study support those of Ozawa and Susskind (1985). We concluded that technical clarity was one critical element in the successful resolution of these conflicts.

TOP OF PAGE

METHODS

We obtained records of 26 hydroelectric power licensing negotiations from field offices of the U.S. Fish and Wildlife Service (FWS). We asked the field office supervisors to select cases they believed to have been successfully resolved. Representatives from these offices were participants in each negotiation and were required to maintain a record of the consultations. Our objective was to follow a most similar system research design (Przeworski and Teune 1970) by selecting the six most similar negotiations for which documentation was available. The cases we chose included one new license and five relicense consultations. The new license case was chosen because of its strong similarity to other cases in terms of applicable licensing regulations (Lamb 1992) and similar parties and issues. The five relicense cases are approximately 25% of all FERC relicenses granted to utilities during the period 1984-1989 (Richard Hunt Associates 1991). All the cases involved at least the utility applicant, FWS, and state fish and game agency; were conducted under the same regulatory regime (Kerwin 1990, Bearzi and Wilkerson 1990, Bearzi 1991); and at least dealt with the environmental issues of streamflow, fish passage, and fish entrainment. These environmental concerns were the most common and time consuming issues faced by parties to FERC licensing consultations during the period 1984-1989 (Richard Hunt Associates 1991).

We tape-recorded structured interviews with 48 key individuals who participated in the negotiations. Data were always collected from representatives of the major parties in each dispute, including the FWS, state fish and game agency, and applicant. Respondents were those assigned by their organizations to actually conduct the negotiations. The interviews took place at the respondent's place of business (two were conducted via telephone) and ranged in duration from 1.5 to 3 hours. All but one of the 7-member study team conducted interviews. Our interview questions were referenced directly to criteria for finding technical clarity and success. We used two stages of analysis to categorize responses according to these criteria: (1) evaluation of transcribed responses by the 2-person interview team; and (2) review of transcripts and interview team evaluations by the entire study team. For each criterion we selected example statements that typified respondent answers.

During the interviews, we asked respondents a series of questions to determine how clearly technical issues were defined during the negotiation process (Table 1). The answers varied from specific examples of how clearly respondents understood the definition and scope of the issues and the required research, to how clearly they understood the resulting data. We also asked respondents to rate technical clarity on a scale from 1 to 10, with 1 meaning the issues were not at all clear and 10 meaning the issues were perfectly clear. During the interviews we traced the history of each case so that changes in technical clarity over the course of the negotiation could be measured. Criteria for determining the clarity of technical issues included: (1) All parties agreed to the definition of the technical issues throughout the process but especially during the stage when final agreement was being forged; and (2) the definition of the technical issues was rated from high to very high (between 7 and 10) by all respondents.

Interviewees were also asked to evaluate the success of each negotiation (Table 2; Fulton 1992; Burkardt et. al 1995). Our criteria to evaluate success included: the parties recognized that an agreement was reached, the agreement included a plan of implementation and post- construction monitoring, there was a willingness to enter into future negotiations with the same parties, and respondents rated success at more than seven on a ten-point scale (where 1 meant no success and 10 meant fully successful). The cases we studied varied from fully successful to minimally successful and in how well the technical clarity criteria were met.

TOP OF PAGE

FINDINGS

Eastman Falls Project

Located on the Merrimack River in New Hampshire, this project is distinctive in that it was one negotiation within the larger framework of the Merrimack River Comprehensive Fish Passage Plan. The major issue was up- and downstream fish passage. As part of negotiations on the Comprehensive Plan a requirement for the project operator to install fish passage facilities had been discussed and agreed upon before the application for a renewal license on the Eastman Falls project was filed. As a result of these earlier discussions, there was a great deal of clarity on technical issues before the license consultation began. Through the Comprehensive Plan, the parties had developed a clear understanding of the scope and scale of the issues, as well as the appropriate methods to resolve those issues. Comments from two respondents illustrate the clarity of technical issues:

The respondents' rating of a high level of technical clarity is illustrated further by the numerical scores. The average score for technical clarity in the consultation was 8.5. This does not mean there were no technical controversies.

For example, controversy surrounded the technical responsibilities of the parties, specifically in terms of jurisdiction. Members of the Technical Committee for the Comprehensive Plan formulated recommendations which they passed on to the Policy Committee. The Policy Committee, in turn, constructed the Comprehensive Plan. In the Eastman Falls consultations that followed, the negotiators were bound to adhere to the terms of the Comprehensive Plan. However, some Eastman Falls negotiators believed that they should have been part of the Technical Committee because they were the appropriate parties to provide input on technical issues and boundaries. In fact, the usual practice was for these negotiators to take the lead in formulating technical recommendations, and the reversal in roles was a stumbling block in completing the consultation.

We judged this negotiation to be successful. There was complete agreement on resolution of the issues and a strong commitment to implement. All parties were willing to negotiate again and respondents reported that relationships improved. Success scores range from 7-10.

Koma Kulshan Project

Like the Eastman Falls project, Koma Kulshan had a distinctive characteristic. This characteristic was that the consultations' main issues-- streamflow (i.e., How much water should remain in the bypassed reach?), sedimentation (i.e., How much sediment would be washed into a downstream lake?), and public access to the small reservoir created by the project--were fully resolved. The respondents credited this to the fact that the physical and biological impacts of the project were expected to be minimal. Once the parties realized the straightforward nature of the environmental effects little conflict ensued. Developing that realization was not easy. Agreeing on a resolution required numerous meetings over several years in which the participants learned to work together, developed a shared technical understanding of project operations (including the difference between pre- and post-project conditions), and constructed a solution. One respondent summarized technical clarity well when he said:

Located in a remote area on the Sandy and Sulphur Creeks in the State of Washington, the project consisted of a water diversion structure and a penstock transferring water to a power generating station. The technical problems in this project proved amenable to resolution. For example, the proposed site for the penstock was occupied by a plant on the State of Washington's list of threatened species. Because an alternative site was available the penstock could be built at a second location. Another problem entailed the effects on trout of altered streamflow in the two streams. Although the parties differed regarding the methods to investigate these impacts, the problem was tractable because so few fish were found in the streams. Finally, the major technical sticking point proved to be sediment transport. As a result of the effective working relationship that had developed over several years of negotiation, the parties were able to develop a means to resolve this issue. Numerical ratings indicated that by the time the consultation ended, all the respondents considered the issues to be clear.

We found that the negotiations over Koma Kulshan were successful. All parties believed that a successful agreement was reached. Eight of the ten parties stated that the final agreement contained provisions for monitoring, other parties did not recall. Each interviewee reported a willingness to negotiate again. Success scores range from 5-10 with 8 of the 10 respondents rating success at 7 or higher.

Oswegatchie Project

The Oswegatchie River Project in New York encompasses six dams located on a seventy mile stretch of river. The project consists of a series of power stations and penstocks that bypass the natural river channel. The principal issue in this negotiation was streamflow in the bypassed reaches. An understanding of the scope and effect of this issue was shared by the parties and was believed to be the only important technical issue. The parties were able to reach agreement on all but one of the bypassed reaches. On this one reach they submitted differing recommendations to the FERC, and FERC made the final decision. One respondent recalled:

Although the question of appropriate flows in the contested bypass reach was clear in the sense that everyone knew that flows in that reach were a stumbling block to agreement, the parties struggled over the conduct and interpretation of studies to assess the effects of altered flows. The struggles among the parties reflected strongly held differences in goals for operation of the project; some parties sought to maximize generation efficiencies while others attempted to maximize instream benefits. Conflicts that manifested as technical differences were actually a reluctance to compromise closely held values. The question of flows in the last stream reach remained intractable because there were no identifiable physical alternatives. Moreover, each party believed it would prevail when the issue was elevated to the FERC. In an effort to bolster its position late in the consultation, the state sought another mechanism to impose its instream flow requirement on the other parties. One mechanism available to the state was section 401 of the Federal Clean Water Act. Under that section, the state is required to issue a water quality certificate indicating whether the project as planned would violate state water quality standards. If a state finds that water quality standards would be violated, it may include provisions in the certificate to protect water quality. The FERC must follow the requirements in a state's section 401 certificate. In this case, the state included an instream flow requirement in its certification and the utility protested that action. Numerical scores for technical clarity were high with a mean overall score of 8. This high score reflects the parties' understanding of the nature of the impasse.

We judged the negotiation to be minimally successful. Agreement was not reached on all points: The state section 401 water quality certification and instream flows were unresolved and the FERC order was contested. Implementation was not a major issue in the negotiation but monitoring was included in FERC order.

All parties reported a willingness to negotiate again. Success scores range from 7-8.

Cataract Project

Ratings for technical clarity in the Cataract Project changed dramatically at different times during the negotiation. Cataract is the downstream-most impoundment on the Saco River in Southern Maine. Water released from the project travels a short distance before emptying into the estuary of the Saco. In the early stages of the consultation, the parties shared an understanding that the issues included instream flow for Cataract and seven upstream impoundments, the need for a comprehensive river plan, and fish passage. Understanding these issues did not preclude disagreement. For example, the exact details of a comprehensive river plan were contentious because the parties could not resolve the question of how far upstream fish passage facilities needed to be constructed.

After the project proponent completed the license application, additional conflicts arose while some existing issues became clearer. For example, the fish passage issue became clearer through a mutual agreement setting an approach to resolving the problem. In this phase, one party introduced the issue of flow releases for waste assimilation downstream of the dam in the form of a state Section 401 water quality certification. This new issue surprised other parties because it was introduced late in the consultation process. Uncertainty about state Section 401 certification was manifested in discussions about whether the state agencies had the authority to include streamflow as a part of their Section 401 certification and whether FERC was bound to include the Section 401 certificate in the license. Because the answers to these questions were unclear the parties responded with low ratings in our quantitative measure of technical clarity. In the final phase--after a license was issued-- technical clarity was reported as high even though the Section 401 flow issue remained unresolved.

As time passed in the Cataract negotiations, some issues were clarified, some muddied, and some discarded. Most disagreements about technical issues revolved around how to make decisions, resolve problems, choose methodologies, and interpret results. The parties understood the issues but could not agree on how to resolve them. One reason for this was that the applicant and some of the parties to the Cataract consultation were simultaneously involved in a very contentious general stream negotiation on the Kennebec River and that process led to skepticism about the Cataract process. The following exchange characterizes the respondents' conclusions about this negotiation:

We rated the Cataract project as minimally successful. Not all parties believed that a satisfactory agreement was reached. The state Section 401 water quality certification, fish passage, and instream flow were unresolved issues. Procedures to implement agreements were included for those issues on which there was agreement. All parties reported a willingness to negotiate again. Success scores range from 2-9.

Ashton-St. Anthony Project

Located on the Henry's Fork River in southeastern Idaho, the Ashton-St. Anthony Project consists of two developments; a dam, reservoir, and powerhouse near the town of Ashton and a diversion dam, canal, and powerhouse within the city limits of St. Anthony. The project was constructed in the mid- 1910's, later acquired by a large regional utility, and scheduled for relicense in 1984. Under FERC rules of that period the relicensing presented an opportunity for a municipality to obtain the new license, to the detriment of the utility.

Because of this competition, the utility sought to streamline the relicensing process by simplifying many technical issues. As the consultation progressed it became obvious that the utility's application would prevail over any competitor and the negotiations over technical issues became more intense. In the early stages, studies were agreed to without discussion on the eventual interpretation of the resulting data; in some cases there seems to have been no mutual understanding of the purpose of the studies.

The license was issued on the condition that further studies would be undertaken. During this second phase there was a lack of agreement on the use of scientific techniques. Although the parties agreed that fish entrainment and turbine mortality of native fishes was an issue and they agreed to conduct studies of those phenomena, they failed to agree on how to quantify losses of native fish due to those causes and they did not discuss how data were to be interpreted. It was during this second phase, too, that the parties realized some of their earlier assumptions about other technical matters had not been accurate. For example, one party was asked to study the reservoir fishery. After the study was completed there was disagreement on study scope, results, and reporting procedures. One respondent reported skepticism about negotiations over technical issues:

Another important factor in this consultation was that the statute guiding the FERC's licensing activities was amended by ECPA in the middle stages of this negotiation, causing all parties to be unsure of the process.

The negotiations were judged to be minimally successful. Only parts of an agreement were finalized. Fish passage, entrainment, and wetlands protection were unresolved issues. Agreements that were reached did include some implementation and monitoring. All parties reported a willingness to negotiate again. Success scores range from 3-10.

Pit 3,4,5

The Pit River of northern California empties into Shasta reservoir on the Sacramento River and is marked by a series of hydroelectric projects. Each project consists of a dam with a downstream reach bypassed by a penstock. Pit 3, 4, 5 is a series of three diversion structures, bypass reaches, and power stations. The project directly affects more than 62 kilometers of river.

Respondents in the pre-license phase reported three phenomena: confusion on what they were trying to accomplish with the consultation, agreement on some issues to study, and disagreement on where studies would lead the parties. One exchange with a respondent illustrates the confusion:

This confusion was due to uncertainty over how to handle the resolution of technical questions and how to move forward. The parties looked to the FERC for leadership but found little, and the direction provided by the applicant did not seem to lead to timely results. Confusion did not arise from disputes over which studies to conduct. Rather, after completing the studies the parties still did not agree on how to interpret the results.

The post-license phase was marked by studies designed to meet license requirements and agreements on several outstanding issues. But the issue of flow release in the Pit 3 bypass reach had not been resolved. After the flow studies were completed the parties could not agree whether the flows were established to promote trout habitat or eagle foraging on Sacramento Sucker. Even within the internal deliberations of one of the parties there was no agreement about this question. Moreover, although the parties did agree that eagle foraging was one important factor, they could not agree how much use by eagles constituted foraging: Did one eagle taking one fish constitute foraging or did foraging require a group of eagles making regular use of the reach?

We rated the negotiation as minimally successful. Agreement was not reached on flows and the FERC order was contested. Implementation was included on those issues agreed to; monitoring was a part of FERC license. All parties reported a willingness to negotiate again. Success scores range from 1-7.

TOP OF PAGE

DISCUSSION

Of the six projects, we evaluated two as fully successful (Eastman Falls and Koma Kulshan), and four as minimally successful (Oswegatchie, Cataract, Ashton-St. Anthony, and Pit 3, 4, 5). The two successful cases were the ones in which technical clarity was most evident (Table 3). Although two consultations were judged to be successful each displayed unique distinguishing features. In Eastman Falls the key feature was the earlier negotiation of a comprehensive plan covering fish passage requirements for the entire river. Mitigation steps required of the Eastman Falls project proponent were understood in advance and the consultation was a matter of conforming to the plan. Questions did arise about the responsibilities of individuals representing some of the parties to the consultation because those representatives had not been a part of the negotiations over the comprehensive plan. However, these questions did not impinge upon the technical clarity of the issues under negotiation.

In Koma Kulshan the issues were streamflow, sedimentation, and public access. Unlike Eastman Falls, there was no previous agreement on these issues. The parties had to decide what the problems were, determine appropriate studies to evaluate alternatives, and design a solution. All of this required considerable time. This was the one case we studied for which no license had yet been issued. Because the project was not in place the parties had the luxury of time to develop a solution. Although the parties were interested in completing the consultation, several non-technical issues delayed the process. The delay allowed time to develop trust-based working relationships. Finally, the parties agreed that the environmental effects of the project would be minor.

The feature that sets these negotiations apart from those that were less successful is that the parties shared an understanding of the technical issues. In both cases this shared understanding arose from a long negotiation; albeit in the Eastman Falls instance that negotiation occurred in a separate forum. In each case the technical issues were straightforward and there was no real question about whether or not the project should be licensed (although this was not clear at the beginning of the Koma Kulshan consultation).

The parties in both consultations were able to resolve (Koma Kulshan) or already had resolved (Eastman Falls) the technical questions related to the heart of the negotiation: What is the extent of adverse environmental effects? That is to say, they resolved the value or ethical questions about the project. Simon (1976) observed that every decision contains both fact and value elements. Factual propositions are those things that can be objectively tested, while values are statements of what ought to be. Values are ethical propositions that "cannot be described as correct or incorrect" (Simon 1976:50). One of the most difficult tasks in the consultations we studied was for the parties to arrive at some ethical premise that would guide their negotiations. In the successful negotiations the parties were either given or developed the premise that it was suitable that the license be granted. Reaching this conclusion was made easier by the fact that the technical issues were straightforward and the environmental effects seemed minor.

The unsuccessful negotiations in our study can be characterized as follows: In two, the technical issues--and to some extent the consultation process--were clear but value considerations intervened. In the other two, the technical issues were never clear, the process was fuzzy, and value considerations were not resolved. Of the minimally successful consultations Oswegatchie and Cataract provide examples of clear technical facts but conflicts over goals. In Oswegatchie flows in one bypass reach were the key to the conflict. The parties differed on the effects of these flows, with the utility believing that releasing the flows significantly reduced the profitability of the project while the agencies believed that their recommended flows in the bypassed reach were essential for fisheries and recreation. Moreover, each party believed that the FERC process favored their position and that if the decision were left to the FERC, their own positions would be upheld.

In Cataract the issues were a comprehensive plan for fish passage on the entire river, fish passage at the Cataract site, and bypass flows. Resolution of this dispute hinged on developing a common objective for all projects on the river. Because it was the most downstream project some parties wanted to use the Cataract licensing process to leverage an agreement that fish passage facilities would be built on all upstream dams. On the other hand, the utility wanted to decide the fish passage question on a project-by-project basis, arguing that when fish migrated up to the next dam, passage facilities could be designed for that project. The parties in Cataract and Oswegatchie understood the facts but disagreed on the values.

Ashton-St. Anthony and Pit 3, 4, 5 provide examples of unclear technical issues, opposing values, and an unclear consultation process. In Ashton-St. Anthony none of the parties was able to articulate clear management objectives--other than the utility's aim to relicense the project. All the parties expressed confusion about how to conduct the consultation. Studies were conducted without agreement on purpose or method. Steps were taken to conduct studies, acquire lands, or perform other mitigation activities without a clear connection to goals beyond meeting milestones in an uncertain process. In Pit 3, 4, 5 instream flow studies were undertaken because it was understood that such studies had been required in other cases. But there was no agreement on the management objective of the studies- -i.e., eagle forage or trout fishery. The parties believed the FERC licensing process was fuzzy. Although the rules governing the FERC process changed during the course of all our cases, Ashton-St. Anthony and Pit 3, 4, 5 negotiations were not near conclusion at the time of the change and respondents cited the changed rules as factors in resolving the conflicts.

Several factors promote technical clarity during negotiations. For example, we found that having a sense of urgency in the negotiation motivated participants to work hard at defining the appropriate technical issues. Conversely, a consultation process that is at once formally required and uncertain in its procedural requirements reduces the sense of urgency. The combination of the right people in the right places was also extremely important. Knowledgeable individuals with well planned objectives and experience in group decision-making are valuable to all sides.

The most successful negotiations we studied focused on two technical elements: First, coming to agreement on desirable conditions (values) and, second, determining how to operate a project to achieve those conditions (facts). In the least successful negotiations, parties attempted to answer the project operation question without resolving their differences over goals. Thus, disagreement over technical issues was a manifestation of underlying differences in approach and philosophy. Achieving technical clarity is difficult. Negotiators often plunged into their task without clearly defining the problem, hoping that a series of studies would illuminate the best course of action (Burkardt et al. 1995). Defining and discussing technical issues and their implications at an early stage may be critical to the ultimate success of a negotiation.

TOP OF PAGE

ACKNOWLEDGMENTS

We are grateful for the work on this project provided by our research assistant Donna L. Lybecker and for the efforts of colleagues on our research team Dr. Carl Armour, Dr. Terry Waddle, David Fulton, and Beth A. K. Coughlan.

LITERATURE CITED

Bearzi, J. A. and W. R. Wilkerson. 1990. Accommodating fish and wildlife interests under the Federal Power Act. Natural Resources and Environment. 4(4):20-58.

Bearzi, J. A. 1991. The delicate balance of power and nonpower interests in the nation's rivers. Rivers. 2(4):326-332.

Burby, J. 1994. Water wizards. Government Executive. 26(11):40-44.

Burkardt, N. B. L. Lamb, and J. G. Taylor. 1995. Technical clarity in inter-agency negotiations: Lessons from four hydropower projects. Water Resources Bulletin. 31(2):187- 198.

Fulton, D. C. 1992. Negotiating successful resource management: An analysis of instream flow mitigation decision processes. MS thesis, Program in Environmental Science and Regional Planning, Washington State University, Pullman, WA.

Kerwin, C. M. 1990. Transforming regulation: A case study of hydropower licensing. Public Administration Review. 50(1):91- 100.

Kerwin, C. M. and J. M. Robinson. 1985. Report to the Office of Hydropower Licensing. Federal Energy Regulatory Commission, Washington, DC.

Lamb, B. L. 1992. Accommodating, balancing, and bargaining in hydropower licensing. Resource Law Notes 25 (April):5-11.

Mnookin, R. H. 1993. Why negotiations fail: An exploration of barriers to the resolution of conflict. The Ohio State Journal on Dispute Resolution. 8(2):235-249.

Ozawa, C. and L. Susskind. 1985. Mediating Science-Intensive Policy Disputes. Journal of Policy Analysis and Management. 5(1):23-39.

Przeworski, A. and H. Teune, 1970. The Logic of Comparative Social Inquiry. Wiley Interscience, New York, NY.

Richard Hunt Associates. 1991. Lessons Learned in Hydro Relicensing (1984-1989): Trends, Costs, and Recommendations. GS-7324, Research Project 3113-2. Electric Power Research Institute, Palo Alto, CA.

Simon, H. A. 1976. Administrative Behavior: A Study of Decision-Making Processes in Administrative Organization. (4th Edition) The Free Press, New York, NY.

Introduction

Methods

Findings

Discussion

Acknowledgments

Literature Cited

Abstract

INTRODUCTION

TOP OF PAGE

METHODS

TOP OF PAGE

FINDINGS

Eastman Falls Project

Koma Kulshan Project

Oswegatchie Project

Cataract Project

Ashton-St. Anthony Project

Pit 3,4,5

TOP OF PAGE

DISCUSSION

TOP OF PAGE

ACKNOWLEDGMENTS

LITERATURE CITED