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Show THE PUBLIC PARTICIPATION PROCEDURES In a letter to me on March 31 of this year, you stated that three options were being presented to the Secretary concerning the type of contract that was needed to take care of the problem facing the Bonneville Unit. Aside from the fact that there was no public participation in arriving at these options, these are the same options that appear to have been presented to the Conservancy over the past year judging from the minutes of the Conservancy Board meetings. The importance of these options is that they set the parameters in which the contract is to be negotiated. Though you may argue that this is not negotiating, that it's the "putting of language on paper" that constitutes negotiating and that these options are preparatory to formal discussion, you are in effect meeting the criteria for public participation under your guidelines. Before we run through the spectrum of events on what we perceive as contract discussions, we would like to restate some of the key sections of these January 2, 1979, Public Participation in Water Service and Repayment Contract Negotiations Procedures. Our questions concern whether the following events constitute a violation of these policies and procedures: "... the policy is to afford the general public an opportunity to provide input into the decision making process regarding Bureau of Reclamation repayment and water service contracts... the terms and the conditions of such contracts including but not limited to, such matters as quantities of water to be furnished, delivery schedules, construction of facilities, terms and conditions of repayments affect a wider range of the general public than the immediate parties to the contract... ample opportunity shall be provided for review and comment on any new, amendatory, or supplemental water service or repayment contract or amendment or supplement thereto." In the accompanying press release on June 9, 1978 to Interior's proposed procedure, Secretary Andrus stated, "under the proposed procedures, all meetings scheduled by the Bureau of Reclamation for the purpose of discussing terms and conditions of any proposed new or amendatory repayment or water service contract would be open to the public as observers." We also find the WPRS proposed public involvement procedures of January 16, 1980 state in 351.7.1: "In order for public involvement to be a genuinely consultive process, Water and Power Resource Service personnel must avoid advocacy and precommitment to any particular alternative prior to decisionmaking... to structure public involvement activities that provide equal opportunities for all individuals and groups to be heard." By reviewing events that have taken place between the Conservancy District and the Bureau from September 1978, where we found evidence that the concept of the repayment program has been a problem from that time all the way up to and including this present month, we feel that we have a pretty good picture as to what has transpired at the District's Board meetings concerning the repayment contract. |
