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INADEQUATE FUNDING Park Service funding is inadequate to implement programs essential to the protection of park waters. To participate effectively in proceedings affecting the protection of the quantity and quality of park waters, the Park Service must develop, analyze and present extensive scientific data. That requires ongoing pro- grams to complete basic inventories of park water resources, develop baseline data, monitor water resource conditions, analyze data, investigate threats, implement remedies and initiate administrative and legal actions, generally on a park-by-park basis. The Park Service took along-needed step toward addressing these needs in 1983 by consolidating its water resource expertise into a Water Resources Division located in Ft. Collins, Colorado. Part of the National Park Service's Natural Resources Directorate, the Division operates through four branches for planning and evaluation, water rights, water operations and applied research. While establishment of the Water Resources Division has substantially strengthened the profes- sional expertise and tech- nical capability of the Park Service in addressing water issues, the Division's resources fall far short of those needed to address the full scope of park water problems. Furthermore, it has become increasingly clear that the protection of park waters also requires ade- quately staffed and funded resource management and research programs in indi- vidual parks and regional offices. Funding for these programs, however, is also far from adequate. Moreover, park data development needs are often particularly demand- ing because Park Service efforts are complicated by the necessity of relying on a patchwork of laws, case law and regulations not designed or developed for protection of park waters. Invoking that legal patch- work often involves highly complex or technical issues, or uncertain and ill-defined regulatory stan- dards. In order to maximize prospects for success, the Park Service is often compelled to anticipate, and prepare evidence to address, an extremely wide range of difficult factual, scientific and legal issues. Funding is frequently unavailable, however, to adequately develop the needed data. As a result, although all citi- zens have a major stake in our parks, both financial and otherwise, we are not providing the funds essen- tial to maintain and protect our major investment in those irreplaceable assets. ^ Lack of funding for programs essential to pro- tect water quantity: The Park Service lacks the fund- ing necessary to participate effectively in proceedings to adjudicate and quantify park water rights. Currently, 44 park units are involved in 38 water right adjudications in nine states and at least 13 addi- tional administrative hearings involving no less than 14 park units in eight states are anticipated in the near future. Extensive and expensive studies are, criti- cally needed in order for the Park Service to demon- strate the quantity and pattern of flows required to protect park values. At Zion National Park, for exam- ple, 11 detailed field studies and additional computer modeling studies were needed to prepare for an impending adjudication that will determine whether, 18 Funding is inadequate for the Parh Service to identify and study, much less remedy, threats to the quantity and quality of parh waters.